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A Dream that became reality…
Civil Rights A Dream that became reality… Civil Rights Welcome to Civil Rights Annual Training. Civil Rights training is federally required annually. So, let’s review.
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Who Needs Training? Civil Rights Local agencies are responsible for training their staff This includes but not limited to: All involved in all levels of administration of any and all Child Nutrition Programs. “Frontline staff” who interact with program applicants or participants Those persons who supervise “frontline staff” It has been asked by many sponsors recently who actually needs Civil Rights Training. State agencies are responsible for training local agencies understand civil rights related laws, regulations, procedures, and directives. It is then the local agency that is responsible for training their staff. This includes all staff involved in all levels of administration of any and all Child Nutrition Programs. “Frontline staff” who interact with program applicants or participants. And of course, those persons who supervise “frontline staff.”
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Federal Reimbursement $$
Sponsor’s Agreement Civil Rights Civil Rights Requirements Federal Reimbursement $$ = This is a reminder that when you became a sponsor of Child Nutrition Programs you signed an agreement to uphold Civil Rights and treat all eligible participants equally with out discrimination and follow the requirements for civil rights in child nutrition programs. Because this is a federally funded program, and you are receiving federal reimbursement dollars, you must adhere to Civil Rights laws. All eligible participants of Child Nutrition Programs are treated without discrimination to benefits.
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Discrimination Definition:
Civil Rights Is differential treatment towards 1 or a group of people in any of the protected classes by either: Intentional Unintentional Neglect Actions or Inaction So let’s review what Discrimination means. Discrimination is defined as giving differential treatment towards 1 or a group of people in any of the federally protected classes by either intention or unintention, neglect or by actions or inaction. So there are many ways discrimination can happen and sometimes without realizing it.
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Protected Classes Race Color National Origin Age Sex Disability
Civil Rights Race Color National Origin Age Sex Disability There are now six federally protected classes: Race, Color, National Origin, Age, Sex and Disability. Religion, no longer is federally protected, however, the state of Oregon still protects religion.
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Recognizing a Civil Rights Complaint
Remember The 4 DDDDs Delay Deny Different Treatment Disparate Impact An easy way to remember how to recognize an Civil Rights complaint is the 4 Ds. Delay, Deny, and Different treatment and Disparate Impact. Does it Delay or Deny benefits or services that others receive? Different Treatment is being treated differently from others to their own disadvantage. Disparate Impact is something which does not seem discriminatory, but has a discriminatory impact in practice. In other words, good intention but bad impact. An example of Disparate Impact might be that a program allows girls to have lunch first. The (good) intent is this action is a polite courteous gesture, "Ladies before gentlemen!" one staff member says. The (bad) impact is staff hold back a disproportionate amount of food for the boys who staff believe have "greater appetites than the girls." A staff member also says, "Besides, with the childhood obesity epidemic, we need to make sure these girls control their portions." While this staff member does have good intentions for the girls' health, she has (hopefully unknowingly) singled them out unfairly. If a person says their civil rights are being affected the complaint must be treated as a civil rights complaint.
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Complaint Procedure Written Procedure in place
Civil Rights Written Procedure in place 180 days to file 2-page complaint form (Must assist complainant, if requested) Notify ODE/CNP within 3 working days of receiving complaint , regardless if resolved or not. A Civil Rights complaint may come in all forms of communication. It may start verbally, in person or by phone, or written in a letter, , fax etc. about a situation that was either said, written, or observed. And it could be a about the way the program’s administered, or over the employment or participants in the program. The complaint may get reported locally and therefore investigated locally and resolved locally, or the complainant may contact USDA, at the federal level, directly as is the contact information given on the Civil Rights Posters. If communicated directly to USDA, State officials would be contacted by the federal level and then the sponsor would be contacted by State. Hence, you might be the last to know. All sponsors of Child Nutrition Programs must have Written Complaint Procedures in place on how to handle Civil Rights complaints provided at all their feeding sites. Click on the first link listed to view a template of already written procedures that State is providing to sponsors to use as their own. Complaintant may have up to 180 days (or six months) to file their complaint from the time of the incident. If requested by the complaintant, Sponsors must assist them in filling out the form. In any case, if a sponsor receives a Civil Rights complaint, regardless if resolved or not, ODE must be contacts within 3 working day of receiving the complaint. Reported locally or directly to USDA
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“And Justice For All” POSTER
Civil Rights Display in a Prominent Location that is accessible to all to read The current “And Justice for all” Poster, is dated May 2008, and must be posted in all feeding sites and in the school office or wherever meals are paid for. The poster must be accessible enough to students and parents so they are able to read it. Color copies of the poster can be requested from the state office or downloadable through our ODE Website at the link listed here at the bottom.
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Nondiscrimination Statement
Civil Rights Nondiscrimination Statement Short Version: “This institution is an equal opportunity provider” (Sponsor Name = “This institution”) Long Version: (As is on Poster) “In accordance with Federal law and U.S. Department of Agriculture policy, this institution is prohibited from discrimination on the basis of race, color, national origin, sex, age, or disability. To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, DC or call, toll free (866) (Voice). TDD users can contact USDA through local relay or the Federal Relay at (800) (TDD) or (866) (relay voice users). USDA is an equal opportunity provider and employer.” There are two possible Nondiscrimination Statements you may use on various school related publications. The current short version is “This institution is an equal opportunity provider” where this institution can be replaced with the Sponsors Name. For example, “Happy Valley SD is an equal opportunity Provider.” The long version of the Nondiscrimination statement comes directly off the poster and is two paragraphs long.
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Usage of Nondiscrimation Statement
Civil Rights Whenever mentioning Child Nutrition Programs in public documents Which Version: Short Version = 1 page (front and back) Long Version = > 2 pages So the question remains which Non-discrimination Statement do I use? First of all, the nondiscrimination statement must be used on sponsor’s publications whenever USDA or any of the child nutrition programs (NSLP, SBP, ASCP, CACFP, SFSP, Commodities, Farm to school, etc…) are mentioned. As far as which version of Non-discrimination statement to use, there is any easy rule of thumb to remember: If only 1 page (front & back) you need only the short version. If greater than a page, use the full long version. See the examples of documentation that may require a non-discrimination statement. Enrollment forms, employee or parent/student handbooks, newsletters, brochures, flyers/advertisement and websites. Menus for any of the participating child nutrition programs, if posted, must always have the short version non-discrimination statement. Document Examples: Enrollment Forms Menus Employee Handbooks Parent/Student Handbooks Newsletters Flyers/Advertisements Brochures Websites
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Civil Rights Documentation
** Every feeding site must have available Annual Training Form Procedures ** Complaint Form, 2 pages ** English Spanish Complaint Log** Keep on file 3 years past + current year, regardless If there are no complaints. Poster** Civil Rights forms and documents are available through our website. As previously mentioned, every feeding site must have the procedures in place and documented at the site. Also required is access to the complaint forms – make sure both pages (front and back) are available. And a complaint log must be kept for 3 years past plus the current year, even if there are no complaints during any of those years. And ,of course, each feeding site must post the current “Justice for all” Poster as mentioned earlier.
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Civil Rights Resources
FNS Instructions, 113-1, Appendix B ODE Civil Rights Specialist - Winston Cornwall, Phone: (503) ODE’s Civil Rights website: Here is a list of Civil Rights Resources for your reference. The FNS instructions are our primary source for Civil Rights Guidance for Child Nutrition Programs. Also our Civil Rights Specialist, Winston Cornwall, can be reached as shown by phone or if ever you have a question or concern. And again, more Civil Rights information and documents and forms are all available at our ODE website. The link at the bottom goes directly to the Civil Rights page.
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Reminders Remember all attendees must sign annual training form
Civil Rights Remember all attendees must sign annual training form Keep signed and dated training form in your records for 3 yrs + current year Do Not Send Training Form into State Congratulations you completed your annual Civil Rights Training for the year! Please remember to have all attendees sign it and keep it in your records for 3 years plus the current year. Do not send in the Civil Rights Training Form into to state as we have changed the procedures.
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Civil Rights Civil Rights
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