SFSP Civil Rights Training - Civil Rights Compliance

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					Civil Rights Compliance
Summer Food Service Programs
What Is Discrimination?

Discrimination is defined as different
treatment which makes a distinction of
one person or a group of persons from
others; either intentionally, by neglect, or
by the actions or lack of actions based

Protected Classes

•   Race
•   Color
•   Sex
•   Age
•   National Origin
•   Disability

Goals of Civil Rights

• Equal treatment for all applicants and
• Knowledge of rights and responsibilities
• Elimination of illegal barriers that prevent or
  deter people from receiving benefits
• Dignity and respect for all

8 Areas of Compliance

•   Public Notification System
•   Data Collection
•   Training
•   Compliance Reviews
•   Civil Rights Complaints
•   Assurances
•   Limited English Proficiency
•   Religious Organizations
Public Notification System

• All sponsors and their sites must display in a
  prominent place the “And Justice For All”,
  nondiscrimination poster .

• All sponsors must have the capability of providing
  informational materials in the appropriate

• The nondiscrimination statement should be
  included on all materials regarding the SFSP that
  are produced for public notification.
“And Justice for All Poster”

11 x 17

Nondiscrimination Statement

 In accordance with Federal law and U. S.
  Department of Agriculture policy, this
  institution is prohibited from discriminating 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, Room
 326-W, Whitten Building, 1400 Independence
 Avenue, SW, Washington, DC 20250-9410 or
 call (202) 720-5964 (voice and TDD). USDA is
 an equal opportunity provider and employer.
Too Big? Try This -

This institution is an equal opportunity

Data Collection

Each sponsor is required to collect ethnic/racial
data at each of their sites.

• On the CNP Web site application each sponsor
  enters the estimated percentage of the ethnic/racial
  makeup of the population.
• As part of first week review the ethnic/racial data
  collection form is filled out during a meal service.
     • Staff can make an observation of ethnicity and race then record
       on the form

Data Collection (continued)

Why do I have to collect racial and ethnic data?
• The data is used to determine how effectively your
  program is reaching potentially eligible children and
  where outreach may be needed.

How long do I have to keep the data?
• Three years plus the current year
• Data should be kept secure and confidential

Compliance Reviews

• Pre-Operational Visit—Takes place before the
  site is approved for operation.
• Site Review—Takes place after a site has been
  approved for operation.
• Special Review—Takes place after a site has
  been approved due to a complaint, data collection,
  or as follow-up to previous non-compliance.

Civil Rights Training

 Local agencies are responsible for
 training subrecipients, including
 “frontline staff” who interact with
 applicants or participants on an annual
  • Should be able to identify a civil rights complaint
    if received
  • Should know what to do if they receive a
  • Understand that it is the basic right of the
    individual to file a complaint.                  13
Civil Rights Complaints

 SFSP Civil Rights Complaints must be
 submitted to Child Nutrition Services or
 directly to USDA as they occur
  • Civil Rights Complaint Record
  • CNS must be notified of all food service
    complaints, - resolved, withdrawn, or

  Forms can be found on our CNS website:          14
Civil Rights Complaints

  • The presence of a procedure will be
    confirmed during the administrative


• Assurances are contractual agreements in which a
  state agency, local agency, or the sub-recipient
  legally agrees to administer Food and Nutrition
  Service (FNS) programs in accordance with all
  laws, regulations, instructions, policies, and
  guidance related to nondiscrimination.
• Compliance is verified through compiling data,
  maintaining records, and submitting required
• Documentation of your assurance to comply with
  all civil right requirements is in your permanent
Limited English Proficiency

• Individuals who do not speak English as their
  primary language and have a limited ability to read,
  speak, write, or understand English.
• Recipients of Federal financial assistance have a
  responsibility to take reasonable steps to ensure
  meaningful access to their programs and activities
  by persons with LEP.

Limited English Proficiency

Primary factors to consider when determining
reasonable steps:
• Number of proportion of LEP persons in the
  eligible service population (The greater the number, the higher the need)
• Frequency of contact in the programs
•Importance of the service provided by the
• Resources available to the recipient/costs

Household applications in other languages can be found at:

Further information on LEP is available at                        18
Religious Organizations

 Equal opportunities for religious
 • Ensures a level playing field for the
   participation of faith-based organizations
   and other community organizations in the
   USDA programs

Civil Rights Tools

• PowerPoint : Civil Rights Compliance in
  Child Nutrition Programs
• DVD : Understanding and Abiding by
  Title VI of the Civil Rights Act
• “…and Justice for All” Poster
• Civil Rights Complaint Record
• Ethnic/Racial Data Collection Form
• FNS Instruction 113-1
Final Words on Civil Rights

 “Memories of our
 lives, of our works
 and our deeds will
 continue in others
 who believe and act
 for fairness and

  Rosa Parks