Illinois State Board of Education Nutrition & Wellness Programs 800/ or 217/

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1 Illinois State Board of Education Nutrition & Wellness Programs 800/ or 217/ Updated March 2016

2 Civil Rights Training This is intended for Summer Food Service Program administrators. Additional materials and staff training resources are available at

3 Goals of Civil Rights To ensure equal treatment for all applicants and beneficiaries To understand rights and responsibilities To eliminate illegal barriers that prevent or deter people from receiving benefits To ensure dignity and respect for all

4 What Is Discrimination? Discrimination is: different treatment which makes a distinction of one person or a group of persons from others; either intentionally, by neglect, or by actions or lack of action

5 USDA Non-Discrimination Policy USDA statutes and regulations prohibit discrimination in Child Nutrition Programs based on: Race Color National origin Sex Age Disability

6 What Is a Protected Class? Any person, or group, who has characteristics for which discrimination is prohibited based on law, regulation, or executive order. Protected classes in Nutrition Programs are: race, color, national origin, sex, age, and disability.

7 Types of Discrimination Age/disabilities Age is sometimes overlooked such as infants and/or children with special needs. Example - sites cannot require that parents bring in special formulas or foods.

8 Types of Discrimination Limited English Proficiency (LEP) Definition: Individuals who do not speak English as their primary language and have a limited ability to speak, read, 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

9 Types of Discrimination Limited English Proficiency (LEP) Primary factors to consider when determining reasonable steps: Number or proportion of LEP persons in the eligible service population Frequency of contact in the programs Importance of the service provided by the programs Resources available to the recipient or costs

10 Types of Discrimination Limited English Proficiency (LEP) Household applications in other languages can be found at Further information on LEP is available at

11 Updates to Civil Rights New Civil Rights Statement New poster Must include full statement in announcements (press releases) New protection against reprisals and retaliations

12 Reprisal/retaliation statement In addition prohibiting discrimination against protected classes, statement includes or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.

13 Clarification Reprisal or retaliation is an act of damage or injury against an entity in reaction to an act of damage or injury done to you. It is - unlawful restraint, coercion or discrimination against complainants, their representatives, witnesses, EEO Counselors, investigators, and other agency officials with responsibility for processing EEO complaints Example usage: Employees didn t speak out about the company s pollution for fear of reprisal. Avoid a hostile environment.

14 History Where Did Our Current Laws Originate?

15 Civil Rights Laws Title VI Civil Rights Act of 1964 Prohibits discrimination based on race, color, and national origin. Title IX of the Education Amendments of 1972 Prohibits discrimination based on sex under any education program or activity that receives federal financial assistance. Section 504 of the Rehabilitation Act of 1973 Prohibits discrimination based on disability.

16 Civil Rights Laws (continued) Americans With Disabilities Act of 1990 Prohibits discrimination based on a disability. Age Discrimination Act of 1975 This Act clarifies and elaborates on the original Civil Rights Act of 1964 by ensuring nondiscrimination in all programs and activities. Civil Rights Restoration Act of 1987 Expands prohibition of discrimination in all areas under jurisdiction of institution.

17 Civil Rights Components I. Assurances II. III. Data collection and analysis Compliance reviews IV. Complaints investigation V. Outreach and education VI. Technical assistance and training VII. Reasonable accommodation VIII.Customer service

18 I. Assurances Assurances are contractual agreements in which a state agency, local agency, or the subrecipient legally agrees to administer Food and Nutrition Service (FNS) programs in accordance with: all laws regulations or policies Instructions and guidance related to nondiscrimination.

19 I. Assurances Your assurance to comply with civil rights requirements is in your Permanent Agreement agreed to each year in your application. Compliance verified through: compiling data maintaining records, and submitting required reports

20 II. Data Collection and Reporting Sites need to establish a system to collect racial and ethnic data. Self-identification - for example, on the household application. Staff can also make an observation of ethnicity and race, then record on site review form RATIONALE: Discrimination is often based on perception, and others would probably have a similar perception to the person doing the coding.

21 II. Data Collection and Reporting Site Review Form (ISBE 67-42)

22 II. Data Collection and Reporting Collect ethnicity data first, then race data Ethnicity categories Hispanic or Latino Not Hispanic or Latino Race categories American Indian or Alaskan Native Asian Black or African-American Native Hawaiian or other Pacific Islander White

23 II. Data Collection and Reporting Why do I have to collect racial and ethnic data? How long do I have to keep the data? The data is used to determine how effectively your program is reaching potentially eligible children and where outreach may be needed. Three years plus the current year Data should be kept secure and confidential

24 III. Compliance Reviews The purpose is to determine if the applicant or recipient of Federal financial assistance is in compliance with civil rights requirements.

25 III. Compliance Reviews Pre-Operational Visit Takes place before approval for operation. Site Review Takes place after a site has been approved and is operating. Special Review Takes place after a site has been approved due to a complaint, data collection, or as follow-up to previous non-compliance.

26 Complaint Investigations Who do I contact? (included in Civil Rights Statement) To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: 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) 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 ; (2) Fax: (202) ; or (3)

27 Complaint Investigations Who do I contact? (Continued) Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) ; or (800) (Spanish).

28 Complaint Investigations Midwest Region For general information, you may write to: Midwest Regional Director, Civil Rights, USDA Food and Nutrition Service, 77 West Jackson Boulevard, 20 th Floor, Chicago, IL or call (312) At ISBE Contact the Illinois State Board of Education, Nutrition Programs at 100 North First Street, Springfield, IL 62777, by phone at (800) or by at

29 Complaint Process Develop a reporting method and train site staff on the importance of processing civil rights complaints in a timely manner. Have a go to person who knows the process Complaints can be written on a form or presented verbally to site staff.

30 Complaint Process Site staff should put in writing all verbal complaints and details surrounding the event as quickly as possible. Complaints MUST be filed within 180 days of incident Best to file as soon as possible after incident. Once complaint at USDA, letter issued within five days.

31

32 V. Outreach and Education Important in order to: Inform community Reach potential eligible participants Ensure and assure program access Pay attention to under-represented groups Ensure information is available in other languages as needed

33 V. Outreach and Education All sites must provide information to eligible participants in the appropriate language concerning the availability and nutritional benefits of the meal program (SFSP).

34 V. Outreach and Education Must have info on: Program Availability Complaint information Non-discrimination statement or link Location, times

35 V. Outreach and Education Methods of Notification: ISBE does statewide Local agencies: Brochures/fliers Letters Internet/website Local media

36 V. Outreach and Education When using graphics, reflect diversity and inclusion.

37 V. Outreach and Education Include non-discrimination statement on all materials that mention USDA programs (including websites, announcements and news releases). However, you do not need to include the statement on menus.

38 Civil Rights 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) Additionally, program information may be made available in languages other than English.

39 Civil Rights Statement To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: 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) 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 ; (2) Fax: (202) ; or (3) This institution is an equal opportunity provider.

40 Civil Rights Statement (continued) At a minimum, the following must be on all materials that mention USDA programs (including websites): This institution is an equal opportunity provider and employer.

41 And Justice for All Poster Prominently display this poster in each food service area so it is visible to participants Display in all administrative offices Poster and text translations for 11 languages

42 And Justice for All Poster English/Spanish posters also available free of charge from ISBE or Telephone: 800/ or 217/

43 VI. Technical Assistance and Training USDA State Agency Local Agencies Frontline Staff

44 VI. Technical Assistance and Training Training is required annually for frontline staff. Teaching tools available on our SFSP website: This PowerPoint presentation Front-line staff PowerPoint presentation

45 Technical Assistance and Training

46

47 Training Tips Cover the basics Provide an understanding of the origin of the requirements; i.e., laws that cover all federally-funded entities Recognize and value differences Use relevant examples and situations to illustrate concepts

48 VII. Reasonable Accommodation ENSURE ACCESS FOR PEOPLE WITH DISABILITIES! Be aware of barriers - Physical - parking lot, entrances and exits, halls, elevators, restrooms Communication - sign language interpreters, Braille signage Need of assistance or service animals Provide alternative arrangements for service

49 VIII. Customer Service Good customer service: Meets the clients needs Courteous and cordial service Provider and receiver have similar expectations Keeps clients coming back!

50 VIII. Customer Service Customers may forget what you said but they'll never forget how you made them feel." - Unknown

51 Amy Bianco, or Naomi Greene, Illinois State Board of Education Nutrition Programs Division 800/ or 217/

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