Child Nutriti on Programs(SNP)

Civil Rights Training

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USDA requires all Child Nutrition staff attend civil rights training annually to prevent discrimination

This training plays a key role in providing excellent services

Training Purpose

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Civil Rights refer to the:Rights of “personal liberty” guaranteed by the 13th and 14th

Amendments to the U.S. Constitution and Acts of Congress Fair and equitable treatment of all customers and employees

What are Civil Rights?

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Eliminate barriers to program benefits Provide equal treatment to all Explain rights and responsibilities Show respect and dignity to all

Goals of Civil Rights

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A protected class refers to any person or group of people who have a characteristic for which discrimination is prohibited by law

Protected classes in the SNP include:RaceAgeColor SexNational OriginDisability

What is a Protected Class?

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All schools must have a system to collect racial and ethnic data of program participants

Self-identification or self-reporting is the preferred method of obtaining data

Visual observation shall be used when the applicant does not self-identify

Data must be maintained for 3 years plus the current year Access restricted to authorized school personnel

Collecting and Reporting Participant Data

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2 Ethnic CategoriesHispanic or LatinoNon Hispanic or Latino

Racial and Ethnic Data

5 Racial CategoriesAmerican Indian or Alaskan

NativeAsianBlack or African AmericanNative Hawaiian or Other

Pacific IslanderWhite

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Inform potentially eligible persons, applicants, participants and grassroots organizations of the availability of the SNP

Display the “And Justice for All” posterOrder via Stacey Macklin at Macklin_S@cde.state.co.us

Include the nondiscrimination statement on all informational materials and websites that describe the SNP

Public Notification

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The U.S. Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.)If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Complaint Form, found online at http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish) USDA is an equal opportunity provider and employer.

Public NotificationNondiscrimination Statement

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Communicate using methods such as: Internet and computer based applicationsNewspaperRadio/television Letters/leaflets/brochuresBulletins

Public Notification

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A school is required to provide food substitutions or modifications if:A medical statement, signed by a licensed physician, is on file and

describes the participant’s disability (as defined in federal regulations) that prevents the participant from eating the regularly offered foods, and

The licensed physician has indicated the substitutions or modifications that the participant needs

For a Standard Operating Template visit: http://www.cde.state.co.us/nutrition/nutriSpecDietaryNeeds.htm

Reasonable Accommodations for Persons with Disabilities

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Example:A parent of a student who has been diagnosed with celiac disease

requests that gluten-free food items be provided to their child at all meals.

What must the school do and how does this relate to civil rights?

Reasonable Accommodation Scenario

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SFAs must take reasonable steps to assure “meaningful” access to the information and services they provide…especially for people with Limited English Proficiency (LEP).

Meaningful access may include: The distribution of SNP meal benefit forms (Applications for

Educational Benefits, household letter and approval/denial letter) in 34 different languages http://www.cde.state.co.us/nutrition/freeandreducedpricepacket

Hiring a bilingual interpreter to assist applicants or participants

Reasonable AccommodationLanguage Assistance

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A school must provide equal access to all eligible participants regardless of race, color, national origin, sex, age, or disability

All participants must be treated in the same manner Each participant receives the same menu items in the same

amountsAll participants are included in meals, snacks, activities, and

discussionsParticipants with special needs will have their needs addressed

based on the severity of the need Standards of behavior are not based on membership in a protected

class

Customer Service

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Skills can help staff provide good customer service and avoid potential civil rights complaints

5 goals: Avoid the desire to blame Improve the situationCommunicate your feelings directly Improve relationships and increase communicationAvoid repeating the situation

Conflict Resolution

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A group of high school students is unhappy about the menu served at school. They decide to write a letter to the editor of the local newspaper instead of speaking directly with the cafeteria manager. The cafeteria manager is unaware of the problem until she faces the angry principal with newspaper in hand. Principal position: Do something about this, I don’t need bad publicity for my school! The principal schedules a meeting at 9:00am today with the unhappy students, the principal, and cafeteria manager.http://www.nfsmi.org/documentlibraryfiles/PDF/20080213055327.pdf

Conflict Resolution Scenarios

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Allegation may be based on race, color, national origin, age, sex or disability

Filed within 180 days; written or verbal SFAs must make an effort to obtain:

Name, address, and telephone number of the complainant The nature of the incident or action The basis on which the complainant believes discrimination exists The names, telephone numbers, titles, and business or personal

addresses of persons who may have knowledge of the action The date(s) during which the alleged actions occurred

Forward the complaint

Complaints of Discrimination

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SFAs should have a written complaint procedure. The procedure should outline: Accepting a Complaint

Verbally and in writing Transcribing a Complaint

Collecting relevant information Forwarding a Complaint

Agency complaints are forwarded to

For a CR Complaint Procedures Template visit: http://www.cde.state.co.us/nutrition/civilrights

SFA Complaint Procedure

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Examines activities to determine adherence with civil rights requirements

Definition of “Noncompliance”: A factual finding that any civil rights requirement, as provided by law, regulation, policy, instruction, or guidelines, is not being adhered to

Compliance Reviews

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Denying an individual or household the opportunity to apply for FNS program benefits or services on the basis of a protected class

Providing FNS program services or benefits in a dissimilar manner on the basis of a protected class (except as a disability accommodation)

Selecting FNS program sites or facilities in a manner that denies an individual access to FNS program benefits, assistance, or services on the basis of a protected class

Examples of Noncompliance

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If non-compliance is indicated, corrective action must be taken immediately to achieve voluntary compliance

Resolution of Noncompliance

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OSN Civil Rights webpage:http://www.cde.state.co.us/nutrition/civilrights

Training sign-in sheet template Training agenda template Complaint procedures template Civil Rights self assessment tool Civil Rights training power point

USDA, FNS Civil Rights webpage: http://www.fns.usda.gov/civil-rights

USDA laws, regulations and guidance Frequently asked questions

Additional Resources

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Questions