Federal Civil Rights Requirements for Contract Agencies 2022-2025
Federal agencies receiving funds must comply with civil rights requirements and ensure contractor compliance. This includes submitting a Letter of Assurance, appointing coordinators, developing a compliance plan, providing staff training, and cooperating with monitoring. Instructions for the 2022-2025 period were issued by DCF and DHS in November 2021, with specific deadlines for compliance activities.
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Civil Rights Requirements for 2022-2025
Topics for Presentation Background for Civil Rights Requirements Requirements for Contract Agencies 2022-2025 Compliance Period Letter of Assurance Civil Rights Compliance Plan Civil Rights Data Analysis Civil Rights Training Civil Rights Monitoring and Complaints Other Requirements 2
Background for Civil Rights Requirements Agencies receiving federal funds must comply with federal civil rights requirements and ensure compliance by contractors DCF and DHS issue joint instructions to contract agencies DWD no longer participating in the joint instructions Instructions cover multi-year period: Current period covers 2018 2021 (DCF, DHS and DWD) New period covers 2022 2025 (DCF and DHS only) Includes programs funded by US DHHS and USDA 3
Requirements for Contract Agencies Submit Letter of Assurance that agency complies with civil rights requirements Designate Equal Opportunity Coordinator and LEP Coordinator for the agency Complete Civil Rights Compliance Plan for agency covering all programs to evaluate compliance with requirements Agency staff complete civil rights training Cooperate with civil rights monitoring and complaint investigations by DCF and DHS 4
2022-2025 Compliance Period Instructions issued by DCF and DHS in November 2021 Letters of Assurance (LOAs) due by January 24, 2022 LOAs for new contractors due by 15th business day after contract start Complete Civil Rights Compliance Plans by March 31, 2022 Keep plan on file at agency Provide plan upon request Submit updated LOAs/attachments as needed during period Submit updates for program or personnel changes 5
Letter of Assurance (LOA) LOA contains assurances that agency complies with federal civil rights requirements Identifies agency officials: Agency official with overall responsibility for civil rights compliance Equal Opportunity Coordinator (EOC) for discrimination complaints Limited English Proficiency (LEP) Coordinator for language assistance Indicates federally-funded programs operated by agency Indicates funding relationship to state agencies Can do combined LOA for all DCF and DHS programs 6
Civil Rights Compliance (CRC) Plan CRC Plan has two parts: CRC plan template Template covers multiple CRC topics Template is checklist with narrative sections Data analyses for customer service and LEP population Analyses forms include data and narrative sections Do separate data analyses for each program Can do combined CRC Plan for all DCF and DHS programs Provide CRC plan upon request 7
Topic Sections of the CRC Plan Nondiscrimination notifications Functions of EOC and LEP Coordinator Meaningful access to services Accessibility of services Discrimination complaints Training for agency staff 8
Civil Rights Data Analysis Customer Service Population Data Analysis Compare demographics of potentially eligible population in the service area with the persons actually served Analyze underserved and disproportionate populations Data sources are US Census data and program data reports LEP Customer Data Analysis Identify primary languages for LEP persons in service area Use results to determine need for translation of documents or notices Data sources are US Census data and program data reports 9
Civil Rights Data Analysis, cont. DCF developing a dashboard for the Census data Sorts data for families, income and language Use dashboard to get potentially eligible population Use program data reports or local data sources to identify the persons served Compare persons served with potentially eligible to identify discrepancies Analyze discrepancies to make services more accessible and reduce disproportionality 10
Civil Rights Training Staff of agencies receiving federal funds must complete civil rights training New staff take in first year, refresher for all staff every 3 years Refresher training every year for USDA programs - Food Share and WIC On-line training available for child care, child support and W-2 staff through Partner Training Team Child welfare, youth justice and other programs must provide their own training 11
Civil Rights Monitoring and Complaints State agencies may monitor contract agencies Desk monitoring - review CRC Plan and ask for information from agency On-site monitoring review plan, ask for information, and evaluate accessibility of agency services Applicants and recipients of services can file a discrimination complaint if denied service or treated differentially Can file complaints with local agency, state agency or federal agency Local agency must provide information about case if contacted by state or federal agencies 12
Other Requirements Subcontractors Local agencies responsible for getting CRC LOAs from subcontractors Can use DCF/DHS LOA and CRC Plan formats with subcontractors Affirmative Actions Plans Contractors file annually with state agency providing funding Affirmative Action Plan format issued by State of WI DOA Supplier Diversity Reports Submit expenditure information to state agency finance unit Vendors register with State of WI DOA 13
Resources DCF Civil Rights Compliance https://dcf.wisconsin.gov/civilrights DHS Civil Rights Compliance https://www.dhs.wisconsin.gov/civil-rights/index.htm 14
Questions ? 15
