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Federal Civil Rights Compliance Training: Guidelines & Requirements

Ensure compliance with federal civil rights laws and regulations by providing guidance to recipients of federal financial assistance. Understand the importance of non-discrimination policies, fair treatment, and equality. Learn about the key laws and regulations, train your staff on civil rights responsibilities, and uphold standards for equality and justice for all individuals.

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Federal Civil Rights Compliance Training: Guidelines & Requirements

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  1. Civil Rights FNS Instruction 113-1

  2. Civil Rights • Civil Rights instruction is applicable to ALL programs and activities who receive Federal financial assistance, whether those programs and activities are federally funded in whole or not

  3. Civil Rights • Federal Financial Assistance is: • Anything of value received from the Federal government • Includes cash grants, training, excess computers, loans, property donations and any other goods or services provided with Federal funds • TEFAP and state commodities constitute Federal financial assistance

  4. Civil Rights • Purpose of Civil Rights training: • Provides guidance and direction to Federal financial recipients and their clients • Explains compliance and enforcement of non-discrimination policies • Promotes fairness and equality of treatment

  5. Civil Rights • Authority provided through: • Title VI of the Civil Rights Act 1964 • Americans with Disability Act • Title IX of the Education Amendments of 1972 • Section 504 of the Rehabilitation Act of 1973 • Age Discrimination Act of 1975 • The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 • Food Stamp Act of 1977 • Executive Order 13166 • USDA Departmental Regulation 4330-2 • 7CFR Part 16, Equal Opportunity for Religious Organizations

  6. Civil Rights • Responsibilities: • Training • Compliance with civil right laws, regulations and requirements • Equal treatment for religious organizations • Public Notification and Assurances • Data collection • Complaint Processing • LEP services – providing other language services • Accommodating persons with disabilities • Conflict resolution • Customer Service

  7. Civil Rights • Civil Rights Training & Oversight: Member Agencies

  8. Civil Rights • Discrimination is prohibited on the basis of: • Race • Color • National Origin • Sex • Age • Disability • Religious Creed • Political Beliefs

  9. Civil Rights • Types of Discrimination: • Disparate Treatment • Discriminating treatment of an individual or class of people based on a particular belief • Disparate Impact • Rules, policies or guidelines not intended to cause discrimination but exclude a particular class of people • Retaliation • Deliberate discrimination as a response or revenge

  10. Civil Rights • Exceptions: • Congress can establish a program that is intended for certain groups of people, and it is not discrimination to exclude those who do not meet eligibility requirements • Examples: WIC, senior programs, children’s programs, etc.

  11. Civil Rights • When Do Civil Rights Rules Apply? • Any time there is any Federal financial assistance • USDA/TEFAP commodities • State commodities • Any training, equipment and other goods and services supported or assisted through Federal assistance

  12. Civil Rights • Requirements: • Treat all people with dignity and respect • Complaints do come to the Foodbank • Display the USDA “And Justice for All . . .” non-discrimination poster in a place where it can be seen by ALL who visit the premises

  13. Civil Rights

  14. Civil Rights • Requirements: • Include USDA non-discrimination statement on all materials and websites that mention USDA funded programs • Provide public notification including: • Posted hours of operation • Program eligibility guidelines • Non-discrimination policy • Procedures to file a complaint

  15. Civil Rights • Requirements: • Maintain confidentiality • No social security numbers • Do not discuss a person’s situation • Collect data when appropriate • USDA/TEFAP Eligibility Form – Form can not be modified or other items attached • Monthly Reporting Form

  16. Civil Rights • Requirements: • Cooperate with State and Federal reviewers • If there is a non-compliance issue, correction of problem is expected • Failure to comply with civil rights rules can lead to loss of Federal financial assistance • Agencies may have to pay back value of the food • Sexual harassment is prohibited

  17. Civil Rights • Requirements: • Advise people on how to file a complaint: • Toll Free: 1.800.795.3272 or 202.720.6382 (TTY) • Regional Director, Civil Rights/EEO 77 W. Jackson Blvd, FL 20 Chicago IL 60604-3591 312.353.3353

  18. Civil Rights • Other Requirements: • Make sure people with disabilities are accommodated • Physical or mental impairment that substantially limits one or more major life activities. Disabilities are not specifically named under the ADA but include mobility, sight, hearing, etc. • Provide other language assistance to persons with Limited English Proficiency

  19. Civil Rights • Limited English Proficiency: • An LEP individual is a person who is unable to speak, read, write or understand the English language at a level that permits him or her to interact effectivelywith health and social services agencies and providers • Must provide language assistance • that results in accurate and effective communication • at no cost

  20. Civil Rights • Language Assistance: • Does not require applicants/clients to: • use family or friends as interpreters • use minor children as interpreters • Must NOT be required to disclose • Proof of immigration/citizenship • Social Security Number

  21. Civil Rights • Equal Opportunity For Religious Organizations: • Prohibits discrimination on the basis of religion, religious belief, or religious character in the administration of Federal funds. • Provided that direct USDA funds do not support any inherently religious activities such as worship or religious instruction.

  22. Civil Rights • Equal Opportunity For Religious Organizations • Religious organizations do NOT have to remove religious art, icons, scriptures or other religious symbols. • No organization that receives direct financial assistance from the USDA can discriminate against a program beneficiary on the basis of religion or religious belief.

  23. Civil Rights • Reminders: • If conflicts occur, remain calm • Follow the platinum rule • Treat people the way they would like to be treated

  24. Civil Rights • Final Steps: • Agencies are responsible for training of their staff and/or volunteers • Use the provided Checklist in your agency • Retain each Checklist for 3 years • Complete and Sign the 2nd Checklist with Your Name and Agency • Pass completed Checklists to the front

  25. Civil Rights Questions?

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