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Civil Rights

Annual Training

Getting Started

This training will take approximately 15 – 30 minutes. At the end of each chapter, there will be a question or two. Answer each question until you get the correct answer. If your first attempt is unsuccessful, please try again until you get the correct answer.

Tell us a little about yourself:

Affiliation*
Please check all that apply

Training Goals

    1
  1. Understand policy & recognition of civil rights
    2. 2
  2. Know system structure precautions to avoid civil rights violations
    3. 3
  3. Understand the purpose of civil rights awareness and training for all program staff & federal tracking of program populations
    4. 4
  4. Identify steps for regulation adherence
    5. 5
  5. Know how to process civil rights complaint
1

Policy & Civil Rights Recognition

What are Civil Rights?

“The nonpolitical rights of a citizen; the rights of personal liberty guaranteed to U.S. citizens by the 13th & 14th Amendments to the U.S. Constitution and by acts of Congress.”

Program Authorities

Title VI of the Civil Rights Act of 1964: Protected race, color & national origin classes
Title VII of the Civil Rights Act of 1991: Prevents employment discrimination
Title IX of the Education Amendments of 1972: Protected sex class
Age Discrimination Act of 1975: Protected age class
Section 504 of the Rehabilitation Act of 1973; Titles II & III Americans with Disabilities Act (ADA) of 1990: Protected disability class
FNS 113-1 and Appendix B: Federal Civil Rights instructions; Office of Civil Rights. Provides information on civil rights compliance and enforcement
Executive Order 13166: Limited English Proficiency (LEP) persons
7 CFR Part 16: Religious organizations may not require program participants to participate in religious activities to receive assistance and may not discriminate against participants based on their religious beliefs.
28 CFR Part 42: Nondiscrimination in Federally
assisted programs
Title 7 Code of Federal Regulations (Parts 247 & 250): Regulations that guide CSFP
Agricultural Act of 2014 (Farm Bill): CSFP Regulation adjustment; no women or children
Congressional Legislation Precedence: CSFP is restricted to those who are 60 years of age or older and fall within 130% of the federal poverty guidelines (as outlined in federal regulations), and therefore take precedent over certain protected bases.
Title 7 Code of Federal Regulations (Part 225): Regulations that guide SFSP
Title 7 Code of Federal Regulations (Part 226): Regulations that guide CACFP

Civil Rights Policy

In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity.

Program information may be made available in languages other than English. Persons with disabilities who require alternative means of communication to obtain program information (e.g., Braille, large print, audiotape, American Sign Language), should contact the responsible state or local agency that administers the program or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339.

To file a program discrimination complaint, a Complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form which can be obtained online at: https://www.usda.gov/sites/default/files/documents/ad-3027.pdf, from any USDA office, by calling (866) 632-9992, or by writing a letter addressed to USDA. The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail to inform the Assistant Secretary for Civil Rights (ASCR) about the nature and date of an alleged civil rights violation. The completed AD-3027 form or letter must be submitted to USDA by:

  1. 1. Mail:
    U.S. Department of Agriculture
    Office of the Assistant Secretary for Civil Rights
    1400 Independence Avenue, SW
    Washington, D.C. 20250-9410; or
  2. 2. Fax:
    (833) 256-1665 or (202) 690-7442; or
  3. 3. Email:
    [email protected]

This institution is an equal opportunity provider.

Participants shall not be…

  • Discriminated against
    – The act of distinguishing one person or group of persons from another, either intentionally, by neglect, or by the effect of actions or lack of actions based on their protected classes
  • Denied benefits or services provided by USDA programs
  • Provided services in different manner than others
  • Segregated or given separate treatment in any matter related to receipt of services
  • Restricted from any advantages or privileges within USDA programs
  • Treated differently than others on program
  • Asked to verify citizenship or immigration status

Religious Institutions

  • The fact that institutions are faith-based or community-based shall not be taken into consideration when determining if the location has the interest and structure to support the actions of a distribution site
  • Faith-based organizations do not need to strip symbols of their faith in areas where USDA foods are being stored and or disseminated
  • Sites shall not separate USDA from their other food assistance program
  • Participants cannot be asked to give or do anything in order to collect their box from the faith-based organization
    • – Attend church
    • – Pray
    • – Profess faith
    • – Participate in religious worship
    • – Give confession
1

Chapter One Quiz

POLICY & CIVIL RIGHTS RECOGNITION

1. Which of the following is NOT a protected civil right class?

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

CORRECT ANSWER

Dietary Preferences is the correct answer.

There are 7 protected civil rights classes that apply to all program participants: race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by UDSA. Dietary Preferences is not a protected class, and is not a barrier to participation in UDSA program.

1

Chapter One Quiz

POLICY CIVIL RIGHTS RECOGNITION

2. Which of the following are potential civil rights concerns?

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct.

Correct answer is: All of the above

All the options are civil rights concerns. Any organization participating in a USDA program must abide by civil rights authority as outlined. Any appearance of an organization discriminating on multiple occasions, racial groups not participating in the program, or allegations by advocacy groups indicates the potential for discrimination and violation of civil rights.

2

Violation Precautions

Site Requirements

  • Participate in annual civil rights training
  • Provide fair and equal treatment of participants and benefit delivery to all interested in the USDA programs
  • Do not discriminate on the basis of reprisal or retaliation for prior civil rights activity
  • Treat all people with dignity and respect
  • Post “And Justice for All” poster in visible location

Public Notifications

The public is given multiple opportunities to be aware of their civil rights. Some of the public notifications for USDA programs are:

  • Program availability: Anyone interested in the program must be made aware of the program and eligibility requirements. Anyone interested must be given the opportunity to apply to participate.
  • Rights & Responsibilities: Given to participants at application. It is the responsibility of the applicant to adhere to their Rights & Responsibilities. It is our responsibility to make participants aware of the Rights & Responsibilities in a language they understand.
  • Submitting a complaint: Gives instructions on how to submit a complaint. The information is printed on the application in the nondiscrimination statement as well as in the Rights & Responsibilities.
  • Non-Discrimination Statement: Variation of this statement will be on all printed or public program materials. If you are creating program materials please contact Utah Food Bank for further instructions on placement.
    – Non-Discrimination Statement (Long):

    In accordance with Federal law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discrimination on the basis of race, color, national origin, sex (including gender identity and sexual orientation), age, disability and reprisal or retaliation for prior civil rights activity. To file a complaint of discrimination, write UDSA, Director, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (866) 632-9992 (voice) or (800) 877-8339 (TTY). USDA is an equal opportunity provider and employer.

    For material too small to permit the full statement you must at the very least add this to all publications in the same font and text as the body of the document:

    – Non-Discrimination Statement (Short):

    This institution is an equal opportunity provider.

  • “And Justice for All” poster: This is the nondiscrimination statement from USDA that shall be posted in a visible area at all sites, it is the responsibility of the participant to read.

Americans with Disabilities Act (ADA)

  • Protected class: disability
  • The Americans with Disabilities Act (ADA) requires reasonable accommodations to be provided to persons with disabilities to give them access to Program benefits
  • What does this mean for you?
    ⁃ Accessibility
    ⁃ Providing services in alternate locations
    ⁃ Provide parking spaces
    ⁃ Sign language interpreters

Limited English Proficiency (LEP)

  • Protected class: national origin
  • Definition: Individuals who do not speak English as their primary language and have a limited ability to read, speak, write or understand English including various accents
  • All agencies must provide “meaningful” access to USDA programs in regards to LEP based on:
    ⁃ The number or proportion of LEP persons
    ⁃ Providing services in alternate locations
    ⁃ The frequency of LEP interactions
  • Can participants provide their own interpreter?
    – Yes; however, they are not required to do so and cannot be required to do so
2

Chapter Two Quiz

VIOLATION PRECAUTIONS

1. USDA program participants who do not speak English are required to bring an interpreter when they come to pick up their food.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct

Participants who do not speak English are not required to bring their own interpreter to pick up their food. As an agency offering UDSA you must try to accommodate the language barrier using bilingual staff, online tools, or other options listed in the training.
2

Chapter Two Quiz

Violation Precautions

2. Where can a participant find instructions on how to submit a complaint based on a protected class?

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct

Information on civil rights is required to be listed on public program documents for participant awareness, as well as a resource on how to submit a report.
3

Staff Training & Data Tracking

Civil Rights Training

  • Training will provide a clear understanding of civil rights related laws, regulations, procedures and directives
  • Training is required annually
  • Who needs it
    – All paid staff who work on the programs
    – All volunteer staff who regularly work with participants, especially during the application process

Data Tracking

  • All states track who is participating in which programs for national demographic information

    Commodities Supplemental Food Program (CSFP)

    Child Adult Care Food Program (CACFP)

    Summer Food Service Program (SFSP)

  • Data for CSFP is requested during the application process. If the participant chooses not to self-identify it is your obligation to guess based on visual cues.
  • Data for CACFP and SFSP sponsors cannot use visual observation and identification to collect race or ethnicity data. Preferred method remains self-identification and self-reporting.
  • CSFP, CACFP and SFSP ethnic and racial data is retained by UFB for 4 years. The required categories are:
    • Ethnicity
      ⁃ Hispanic or Latino
      ⁃ Not Hispanic or Latino
    • Race
      ⁃ American Indian or Alaskan Native
      ⁃ Asian
      ⁃ Black or African American
      ⁃ Native Hawaiian or other Pacific Islander
      ⁃ White

The Emergency Food Assistance Program (TEFAP)

  • Racial and ethnic data is not collected for TEFAP. Household size and income eligibility are collected on TEFAP signature sheets by self-declaration only.
  • TEFAP signature sheets are retained by the agency for 4 years.
3

Chapter Three Quiz

Staff Training & Data Tracking

1. Training is required

Correct

All paid staff and volunteers who have continued contact with program participants are required to attend training annually.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).
3

Chapter Three Quiz

Staff Training & Data Tracking

2. CSFP, CACFP and SFSP track who is participating in which programs for national demographic information.

Correct

USDA requires all demographic information to be tracked and reported annually. By tracking data USDA is able to determine if ethnic groups are being discriminated against with program services.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).
3

Chapter Three Quiz

Staff Training & Data Tracking

3. Race and ethnicity is not tracked for TEFAP

Correct

Race and ethnicity is not tracked for TEFAP and agencies do not need to ask or provide this information.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).
4

Regulation Adherence

Compliance Reviews

Occurs every year at all levels, unless otherwise specified and revolves around the following topics:

  • Equal opportunity for participation
  • Office displays nondiscrimination poster in a conspicuous location
  • Nondiscrimination statement on all printed program materials
  • Program information is made available to potential participants
  • Civil rights complaints are being handled in accordance to training
  • Annual civil rights training conducted and documented for staff

Assurances

  • Sites agree to operate in compliance with all nondiscrimination laws, regulations, instructions, policies and guidelines
  • All options are outlined in the Agency/Site Agreement with UFB
4

Chapter Four Quiz

Compliance Reviews

1. As part of the contractual agreement with UFB each site assures that it will operate in compliance with all nondiscrimination laws, regulations, instructions, policies and guidelines.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct

The UFB agreement outlines the laws, regulations, instructions, policies and guidelines each site must adhere to. For more information please refer to the UFB agreement.
5

Complaint Processing

Receiving a Complaint

  • All complaints alleging discrimination on the basis of race, color, national origin, sex (including gender identity and sexual orientation), disability, age or reprisal or retaliation for prior civil rights activity, either written or verbal, must be processed within the time frames established by Departmental regulations and agreements
  • Any person or representative alleging discrimination based on the identified bases has the right to file a complaint within 180 days of the alleged incident
  • If you receive a complaint submit it to Utah Food Bank ASAP. The organization shall submit it to the appropriate state agency within 5 days of receipt. All complaints must be processed within 90 days of receipt

Forms of Complaints

  • If you receive a verbal complaint document as much information as possible and all their contact information
    ⁃ Who, what, where, when, why, how…
  • Complaints may be received in many written forms
    ⁃ Verbal
    ⁃ Phone
    ⁃ Letter
    ⁃ Email
    ⁃ Fax
    ⁃ Anonymously

FNS 113 Complaint Processing Procedures & Timeline

Customer Service

  • Treat all participants with dignity and respect
  • Recognize that participants have varied needs and (sometimes) few resources
  • Don’t talk or joke about people, regardless of whether they can hear or understand you

Conflict Resolution

  • Respond to questions in a nonthreatening manner and voice tone
  • Develop good listening skills and make eye contact
  • Don’t take anything personally, avoid arguing
  • Most people just want to be heard
    ⁃ Listen
    ⁃ Reiterate the facts, do not use blame
    ⁃ De-escalate the conflict
    ⁃ Document everything
5

Chapter Five Quiz

Complaint Processing

1. Good customer service and conflict resolution skills may assist in preventing allegations of civil rights discrimination.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct

Good customer service and conflict resolution skills help staff treat each participant with dignity and respect, even if the participant is not offering the staff member the same courtesy.
5

Chapter Five Quiz

Complaint Processing

2. Which of the following are tactics of conflict resolution?

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct

Conflict resolution requires eye contact, good listening skills, non-threatening body movements and a normal voice tone. All these tactics will deescalate any situation and lead to a calm resolve.
5

Chapter Five Quiz

Complaint Processing

3. Allegations of discrimination should be put in writing by the complainant or by the staff receiving the complaint. If it is taken by site staff Utah Food Bank must be notified and will assist in forwarding the complaint.

Incorrect.

Please try again. Select another answer from the list above (do not refresh the page).

Correct

Civil rights violations are taken very seriously. If any staff member hears of a violation it must be documented in as much detail as possible.

“Do unto others as you would have others do unto you.”

Follow the Golden Rule to avoid any semblance of discrimination or Civil Rights violation.