Commodity Supplemental Food Program (CSFP) The Emergency Food Assistance Program (TEFAP) California Department of Social Services 1
Agenda Definition Regulations and Authorities Civil Rights Training Racial and Ethnic Data Collection Protected Classes Complaint process Sample Scenario 2
Training Objectives Recognize Understand Accommodate Identify Record 3
What are Civil Rights? Civil Rights are the rights of individuals to receive equal treatment (and to be free from unfair treatment or discrimination) based on certain legally protected classes. 4
Why is this Training Required? $ CSFP & TEFAP Federal Programs Must be annual Process for Complaints Meets obligations 5
Civil Rights Legal Authorities 6
What is Discrimination? Different treatment of one person or a group of persons from others; either intentionally, by neglect, or by the actions or lack of actions based on the protected classes. 7
Examples of Discrimination 8
Protected Classes for our Program Race Color Age •Sex 9 •Disability •National Origin
Who Needs Civil Rights Information? Food Bank program staff • Front Line staff and volunteers • Volunteers and staff that work with the • participants regularly or occasionally Staff that handle personal information • 10
How often? Annually http://www.cdss.ca.gov/inforesources/EFAP/Policies -and-Notices 11
How often for Non Front-line? Every three years http://www.cdss.ca.gov/inforesources/EFAP/Policies 12 -and-Notices
What is necessary? Public Notification Program availability Rights and responsibilities Policy of nondiscrimination Procedure for filing a complaint 13
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) 877-8339. 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: http://www.ascr.usda.gov/complaint_filing_cust.html, 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) 632- 9992. 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. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 14 This institution is an equal opportunity provider.
Nondiscrimination Statement Requirements 15
Components of Public Notification The USDA nondiscrimination poster "And Justice for All" must be prominently displayed in a place where it can be seen. 16
SHORT Nondiscrimination Statement- “This institution is an equal opportunity provider” “Esta institución es un proveedor que ofrece igualdad de oportunidades” (Spanish) 17
Complaints of Discrimination A civil rights Age complaint must be based on one National Race Origin or more of the following: Disability Color Sex 18
Develop a Procedure and a Plan Civil Rights Coordinator Reminder Verbal Written Observed Must Sign complaint form 19
Program Discrimination Complaint Form English http://www.ocio.usda.gov/sites/def ault/files/docs/2012/Complain_co mbined_6_8_12.pdf Spanish http://www.ocio.usda.gov/sites/def ault/files/docs/2012/Spanish_For m_508_Compliant_6_8_12_0.pdf 20
How to Handle a Complaint? • Create a complaint log Relevant Information Maintain for 3 years plus current • Process incoming complaints • Track the complaint 21
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) 877-8339. 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: http://www.ascr.usda.gov/complaint_filing_cust.html, 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) 632- 9992. 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. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 22 This institution is an equal opportunity provider.
Racial and Ethnic Data Collection CSFP Program Only* Local agencies (Food Banks) and sub distributing sites are required to obtain data by race and ethnic categories on potentially eligible populations, applicants and participants in their service area. 23 *Applies to CSFP only
What is Limited English Proficiency? Individuals who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English. 24
Limited English Proficiency (LEP) Requirements These services may include: – Providing interpreters – Providing printed materials in different languages – Bilingual staff When required – Frequent contact greater duty 25
Americans with Disabilities Act (ADA) What is it? • prohibits discrimination against people with disabilities. Who is protected by ADA? • individuals with disabilities. 26
ADA Mandates Reasonable Accommodation Reasonable accommodation is a modification/adjustment to enable individuals with disabilities to have equal access to benefits and privileges of a service or program. 27
Equal Opportunity for Faith Based Organizations Religious art, icons, CANNOT include scriptures or prayer during food other distribution religious symbols Prayer must occur at a different time Federal funds and/or location than the food distribution 28
Civil Rights Reviewed Compliance Reviewed during: • Administrative Review • Complaint Investigation • Annual Renewal process 29
Civil Rights Review Verifies Availability of Civil Rights Information Complaint procedures are in place Complaint procedures comply with Federal requirements USDA “And the Justice For All” Poster displayed Nondiscrimination statement is included on all program materials produced for public information, public education or public distribution 30
Civil Rights Review Also Verifies Materials provided in the appropriate language of the population being served Civil Rights complaints are processed properly Reasonable accommodations Required training for staff 31
Resolution of Noncompliance If noncompliance is indicated, corrective action must be taken immediately to achieve voluntary compliance. 32
Sample Scenario #1 A person in a wheelchair complains that the site where he was told to pick up his food package is not accessible to public transportation. Question: What steps could be taken in this situation? How can this person be accommodated? Answer: Offer home delivery services options and appointing a proxy 33
Sample Scenario #2 A participant tries to speak with a volunteer at a CSFP or TEFAP distribution site in a language other than English, but the volunteer cannot understand the participant. The participant leaves without being served. Answer: Some agencies and Question: How should sites have commonly used that situation have phrases printed on cards to help been handled by the with communication. volunteer? 34
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