1. DARE TO CARE FOOD BANK Louisville, KY Sept 28, 2017 (for FFY17) TEFAP & CSFP Civil Rights Training

2. Civil Rights Compliance
The TEFAP program is governed by laws, regulations, and executive orders that prohibit discrimination based on race, color, national origin, age, sex or disability.
Civil rights training is federally mandated by USDA Food and Nutrition Service to inform and update staff of their obligations under the Civil Rights laws and regulations.
Annual training is required of all TEFAP agencies.
Each food bank/pantry/soup kitchen must maintain a civil rights training file documenting date and attendance for training. The file should include a signature sheet for both annual and new employee training.
FNS was updated and amended to combine all previous instructions on 11/8/05. Changes affecting the Women, Infants and Children Program include the Civil Rights Statement, definitions, and a more defined emphasis on persons with Limited English Proficiency.

3. The Civil Rights Movement
Civil Rights are the nonpolitical rights of a citizen; especially ; the rights of personal liberty guaranteed to United States citizens by the 13th and 14th amendments to the Constitution and by acts of Congress
Federal Civil Rights Act of 1964
Federal Rehabilitation Act of 1973
Title IX of the Education Amendments of 1972
The Age Discrimination Act of 1975
The Americans with Disabilities Act 1990
Title VI of the Civil Rights Act of 1964: Established the concept of protecting certain classes of persons defined as “protected classes”.
Title VII of the Civil Rights Act of 1964: Protecting persons from discrimination in programs receiving financial assistance..
Title IX of the Education Act of 1972: Prohibits discrimination on basis of sex in educational programs / activities that receive or benefit from federal financial assistance. A provider may not exclude, deny or provide different or lesser services to applicants or beneficiaries on basis of sex.
Section 504 of the Rehabilitation Act of1973: Prohibits discrimination on basis of disability by recipients of federal financial assistance.
The Age Discrimination Act of 1975: No person in US shall on basis of age be excluded from participation in, denied benefits of, or subjected to discrimination under any program activity receiving federal financial assistance. (It is not age discrimination if Congress put in age requirements for a program like WIC or senior citizen component of commodities.)
The Americans with Disabilities Act of 1990: Prohibits discrimination on basis of disability by both public and private entities, whether or not they receive federal financial assistance.

4. USDA Nondiscrimination Statement
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) Additionally, program information may be made available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C ; (2) fax: (202) ; or (3)
This institution is an equal opportunity provider.
180 days to file a complaint

5. Indiana Addendum
In accordance with Indiana law, this program is prohibited from discriminating on the basis of religion. To file a complaint of religious discrimination: On basis of religion: Indiana Civil Rights Commission Indiana Government Center N North Senate Ave Indianapolis, IN All other cases: USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, DC

6. Religious Organizations
Must not discriminate against applicants/participants based on religion, religious belief, refusal to hold a religious belief, or refusal to attend or participate in a religious practice.
May not engage in explicitly religious activities as part TEFAP.
Must not require applicants/participants to participate in explicitly religious activities in order to receive food, including worship, religious instructions, or proselytization.
If any explicitly religious activity takes place at a distribution site, it must be separate in time or location from USDA food distribution activities.

7. Religious Organizations TEFAP Specific Requirements
Must display the “Written Notice of Beneficiary Rights” poster prominently where it is visible upon entering the facility.
Must provide the list of TEFAP outlets to clients who want a referral.

8. Religious Organizations CSFP Specific Requirements
Must provide individual written notice to applicants at the time they apply for CSFP benefits.
“CSFP Written Notice of Beneficiary Rights”

9. Example Do’s & Don’ts for Religious Organizations Operating TEFAP
It is acceptable to …
It is unacceptable to …
Have a cross hanging on a wall at the food distribution facility.
Require participants to stand by the cross and recite a prayer prior to receiving USDA foods.
Have a menorah on a table the food distribution facility during the holiday season.
Refuse USDA foods to participants who do not practice the Jewish faith.
Have a display stand at the front/back of the facility that contains faith-based pamphlets for anyone interested.
Insert faith-based pamphlets in bags or boxes when distributing USDA foods.
Have a pastor or other religious official assist with the distribution of USDA foods.
Force or encourage participants to have a religious conversation with the pastor or official prior to receiving USDA foods.

10. Civil Rights Complaints
If an applicant believes they have been discriminated against on one of the protected classes (race, color, national origin, sex, age, or disability) he/she has 180 days to file a complaint
At no time shall a TEFAP representative discourage, impede or ignore a civil rights complaint.

11. Complaint Event
As a TEFAP representative, it is your responsibility to assist an applicant if they have or want to file a complaint . A TEFAP volunteer/staff member is required to:
Complete a Civil Rights Discrimination Complaint
Mail complaint to the USDA office
Mail copies of the complaint to the state TEFAP office, the USDA Civil Rights Director and the Regional Civil Rights Director
The complainant must be advised of confidentiality and Privacy Act Applications when completing the complaint process.
Justice For All Poster has the information in English & Spanish
Must Be Displayed

12. Complaint Event Keep a copy of the complaint at your office
Document the complaint in the outlet log or other applicable document(s).
IF the complaint is verbal or the participant/applicant refuses to put the complaint in writing, make every effort to gather the following information:
Name, address, phone and other means of contacting the complainant.
Specific location and name of entity or person delivering the service or benefit and the nature of the incident or action.
Basis on which the complainant feels discrimination occurred.
Names, addresses, and phone numbers of persons that may have knowledge of the discriminatory action.
The date(s) during which the alleged action occurred.
Start a file to record the events
Document even verbal complaints
Purchase an inexpensive notebook to have available to front line managers & volunteers!

13. Effective public notification Complaint procedures
Everyone should be familiar with Civil Rights compliance in the day-to-day operation of federally funded programs.
Data Collection
Effective public notification
Complaint procedures
Requirements for reasonable accommodation of persons with disabilities
Requirements for language assistance
Conflict resolution and customer service

14. Poster must be displayed in a prominent location
Participants must have access to the Civil Rights Complaint form.

15. Limited Literacy
Agency Staff are responsible for reading the “And Justice for All” poster and Complaint Notice for those who are unable to read.
“And Justice for All” must be translated for
all non-English speaking participants.
Agencies that fail to provide services to LEP potentially eligible applicants/participants or deny them access to federally assisted programs and activities may be discriminating on the basis of national origin in violation of Title VI and its regulations.

16. Communication Resources
Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at
(202) (voice and TTY).
In Indiana, for relay (hearing impaired) services call 711 or

17. Civil Rights Statement Guideline
The Civil Rights statement is required on all program materials such as outreach pamphlets and certificate of eligibility. Where the full statement does not fit, use
This institution is an equal opportunity provider.
in type no smaller than the main body of the document.
Eligibility forms are to be used as supplied and never modified.

18. Questions?