Annual Mandatory Civil Rights Training for School Nutrition Programs

Participants in School Nutrition Programs must undergo annual mandatory civil rights training to ensure compliance with federal laws. Training covers topics such as public notification systems, nondiscrimination statements, data collection, language proficiency, and more. Documentation of training provided to staff must be maintained by School Food Authorities to uphold program integrity and ensure understanding of civil rights obligations.

• Civil Rights Training
• School Nutrition Programs
• Federal Compliance
• Annual Training
• Program Integrity

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1. Civil Rights in the SNP 2023 2024 Begin Course Click Arrow to Begin Home Button Found on each page. Selecting the Found on each page. Selecting the Found on each page. Selecting the Home Button Found on each page. Selecting the Home button returns you to this page. Home button returns you to this page. Home button returns you to this page. Home button returns you to this page. Home Button Home Button Shortcut Buttons These buttons link to major sections of this course. Double-Click to navigate. Topic 8 H Topic 5 Topic 6 Topic 7 Topic 8 Topic 2 Topic 3 Topic 4 Topic 1 Topic 5 Topic 6 Topic 7 Topic 2 Topic 3 Topic 4 Topic 1

2. N NAVIGATION AVIGATION School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Navigation is pretty basic. Back Button, Forward Button, and Home Button. Forward Button Back Button Found on each page. Selecting the Back button returns you to the previous page. Found on each page. Selecting the Forward button advances you to the next page. Home Button Found on each page. Selecting the H H H H H H H H Home button returns you to the very beginning page. H H H H

3. T TOPIC OPIC 1 | M 1 | MANDATORY ANDATORY C CIVIL IVIL R RIGHTS IGHTS T TRAINING RAINING Participants will: 1. State who must receive Civil Rights training. 2. Name the topics that must be included in the Civil Rights training. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Annual Civil Rights Training Is Mandatory Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Civil rights training is required so that individuals involved in all levels of administration of programs that receive federal financial assistance understand federal laws, regulations, instruction, policies, and other guidance. School Food Authorities (SFAs) must annually complete training for all staff that interact with program applicants or participants, or has school nutrition program responsibilities (e.g., frontline staff and their supervisors, free/reduced application approval staff). All new staff must receive civil rights training before they begin work in the School Nutrition Programs (SNP). Program volunteers must also receive training appropriate for their roles and responsibilities, which is available on the School Nutrition Toolbox (SNT) (www.schoolnutritiontoolbox.org). The SFA must maintain documentation on file of the annual civil rights training provided to their staff. Documentation should include: attendance sheets, agendas, copies of training materials, and certificates of completion. H H H H H H H H H H H H Continued on next slide. 3

4. T TOPIC OPIC 1 | M 1 | MANDATORY ANDATORY C CIVIL IVIL R RIGHTS IGHTS T TRAINING RAINING, P , PAGE AGE 2 2 Mandatory Training Topics United States Department of Agriculture (USDA) requires that all food service staff annually receive training on all aspect of civil rights compliance, which is provided by this SNT training. Topics must include: Assurances School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Public Notification Systems Nondiscrimination Statement And Justice for All Poster Complaint of Discrimination and Procedures Racial and Ethnic Data Collection Limited English Proficiency (LEP) and Program Access Disability Discrimination Compliance Reviews Resolution of Noncompliance Conflict Resolution and Customer Service H H H H H H H H H H H H 4

5. T TOPIC OPIC 2 | D 2 | DISCRIMINATION ISCRIMINATION Participants will: 1. Define discrimination. 2. Name the characteristics that make a person part of a protected class. 3. State who must be in compliance with nondiscrimination laws, regulations, instructions, policies, and guidelines. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here What is Discrimination? Different treatment that makes a distinction of one (1) person or a group of persons from others: either intentionally, by neglect, or by actions or lack of actions based on a protected class. A Protected Class Although not a protected class, reprisal can only be filed if there has already been a complaint filed and the complainant is now being discriminated due to filing the complaint. Race Color National Origin Sex (including gender identity and sexual orientation) Age Disability Reprisal or Retaliation for previous civil rights activity H H H H H H H H H H H H Continued on next slide. 5

6. T TOPIC OPIC 2 | D 2 | DISCRIMINATION ISCRIMINATION, P , PAGE AGE 2 2 Assurances SFAs receiving federal funds must be in compliance with all nondiscrimination laws, regulations, instructions, policies, and guidelines. Sub-recipients (entities that receive federal funds from the SFA) must also include a civil rights assurance of nondiscrimination. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Example: SFAs contracting with Food Service Management Companies (FSMCs) are responsible for ensuring that their FSMCs are in compliance with civil rights requirements. H H H H H H H H H H H H 6

7. T TOPIC OPIC 3 | P 3 | PUBLIC UBLIC N NOTIFICATION OTIFICATION Participants will: 1. Describe the required components of a public notification system. 2. Name the places where the Nondiscrimination statement must be included. 3. Describe methods of public notification. 4. State where the And Justice For All poster must be displayed. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Public Notification All Food and Nutrition Service (FNS) assistance programs, including SNP, must have a public notification system that includes: Program availability: Inform applicants, participants, and potentially eligible persons of their program rights and responsibilities, and the steps necessary for participation. Complaint Information: Must advise applicants and participants at the service delivery point of their right to file a complaint, how to file a complaint, and the complaint procedures. Nondiscrimination Statement: All informational materials and sources, including websites, must contain the Nondiscrimination Statement. The Nondiscrimination Statement should not be smaller than the smallest font used within the document. H H H H H H H H H H H H Continued on next slide. 7

8. T TOPIC OPIC 3 | P 3 | PUBLIC UBLIC N NOTIFICATION OTIFICATION, P , PAGE AGE 2 2 Public Notification(continued): At a minimum, the Nondiscrimination Statement must be included on: Household Application for Free and Reduced Price Meals School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Notification of Eligibility or Ineligibility Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Notice of Adverse Action form Program website (home web page) Public information, including program literature that advertises program availability Note: the Nondiscrimination Statement is not required on Menus. H H H H H H H H H H H H 8

9. T TOPIC OPIC 3 | P 3 | PUBLIC UBLIC N NOTIFICATION OTIFICATION, P , PAGE AGE 3 3 Methods of Public Notification The Pennsylvania Department of Education (PDE) publicizes a statewide public notification of program availability annually on behalf of all SFAs in the state. If the SFA wants to notify the public locally using the PDE press release, it is available on Pennsylvania Electronic Application and Reimbursement System (PEARS) > Applications Tab > Download Forms > Resources section. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here SFAs must inform program applicants or participants of changes in programs. SFAs must convey the message of equal opportunity in all photographic or pictorial program information. SFAs must prominently display the "And Justice For All" poster in Food Service areas. SFAs must provide information in alternative ways for individuals with disabilities and LEP. PDE, Division of Food and Nutrition (DFN), encourages the use of this document in its entirety; however, in special circumstances, This institution is an equal opportunity provider and employer may be utilized only with prior approval of PDE, DFN. H H H H H H H H H H H H Continued on next slide. 9

10. T TOPIC OPIC 3 | P 3 | PUBLIC UBLIC N NOTIFICATION OTIFICATION, P , PAGE AGE 4 4 Methods of Public Notification (continued): School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 10

11. T TOPIC OPIC 3 | P 3 | PUBLIC UBLIC N NOTIFICATION OTIFICATION, P , PAGE AGE 5 5 And Justice for All Poster All Food and Nutrition Service (FNS) assistance programs, including SNP, must have a public notification system that includes: The And Justice for All Poster (version AD-475-A) was recently revised in accordance with Section 508. It will be available to print from: https://www.ascr.usda.gov/sites/default/files/JFAgreen508.pdf. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Posters are available from DFN. SFAs must prominently display the And Justice for All poster in Food Service areas. The And Justice for All poster is required to be displayed in the cafeteria area at all times. If students never come to the cafeteria to eat meals, then the And Justice for All poster must be displayed in the area that they eat, e.g. their classroom. H H H H H H H H H H H H 11

12. T TOPIC OPIC 4 | C 4 | COMPLAINTS OMPLAINTSOF OF C CIVIL IVIL R RIGHTS IGHTS D DISCRIMINATION ISCRIMINATION Participants will: 1. Describe the procedures that must be followed in response to a Civil Rights complaint. Complaints of Civil Rights Discrimination School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Procedure for FNS Civil Rights Complaints, PDE, DFN. Put Course Name Here Put Course Name Here 1. Sponsor receives a Civil Rights complaint from the complainant (e.g., parent). a) Sponsor must inform complainant of Federal Civil Rights rules and regulations that have been established for protected classes. (A protected class is any person or group of people who are protected from discrimination based on): 1) Race 2) Color 3) National Origin 4) Age 5) Sex (including gender identity and sexual orientation) 6) Disability H H H H H H H H H H H H Continued on next slide. 12

13. T TOPIC OPIC 4 | C 4 | COMPLAINTS OMPLAINTSOF OF C CIVIL IVIL R RIGHTS IGHTS D DISCRIMINATION ISCRIMINATION, P , PAGE AGE 2 2 Complaints of Civil Rights Discrimination Procedure for FNS Civil Rights Complaints, PDE, DFN. 1. Sponsor receives a Civil Rights complaint from the complainant (e.g., parent) (continued). School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox b) Sponsor must provide complainant the necessary information to file a complaint, which is: Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here 1) Mailing address of the USDA: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-941 2) USDA s Telephone/Fax numbers and Email address: Phone: (866) 632-9992 FAX: (202) 690-7442 Email: program.intake@usda.gov 3) Electronic link to file a civil rights complaint: https://www.usda.gov/sites/default/files/documents/USDA-OASCR%20P-Complaint-Form- 0508-0002-508-11-28-17Fax2Mail.pdf Note: If the sponsor is unsure if the complaint falls under a protected class, sponsor should provide complainant the federal complaint information. H H H H H H H H H H H H Continued on next slide. 13

14. T TOPIC OPIC 4 | C 4 | COMPLAINTS OMPLAINTSOF OF C CIVIL IVIL R RIGHTS IGHTS D DISCRIMINATION ISCRIMINATION, P , PAGE AGE 3 3 Complaints of Civil Rights Discrimination Procedure for FNS Civil Rights Complaints, PDE, DFN.: 1. Sponsor receives a Civil Rights complaint from the complainant (e.g., parent) (continued). School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox c) After providing the complainant with the information on how to file a Civil Rights complaint directly at the Federal level, the sponsor may attempt to resolve the complaint if it is a matter that can be resolved quickly. Resolving complaints in real-time at the lowest possible level is encouraged. (*Note: This is not an investigation as neither the sponsor nor the State agency has the authority to conduct complaint investigations. This is simply trying to resolve the situation if it was potentially caused by a miscommunication.) Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here If the complainant refuses to discuss the matter any further with the sponsor or if the matter cannot be resolved quickly, then the sponsor should: 1) Reiterate the complaint filing procedures in 1)b); 2) Document the complaint and actions taken (i.e. referral to Federal complaint procedures) in a Civil Rights complaint log that is separate from any other complaint log, (*Note: A separate Civil Rights complaint log is necessary due to confidentiality and privacy laws. See complaint log requirements in d) below); and 3) Notify the State agency of the discussion. (*Note: it is important for the sponsor to notify the State agency because regular communication between the sponsor and State agency is key to operating the program successfully.) H H H H H H H H H H H H Continued on next slide. 14

15. T TOPIC OPIC 4 | C 4 | COMPLAINTS OMPLAINTSOF OF C CIVIL IVIL R RIGHTS IGHTS D DISCRIMINATION ISCRIMINATION, P , PAGE AGE 4 4 Complaints of Civil Rights Discrimination Procedure for FNS Civil Rights Complaints, PDE, DFN.: 1. Sponsor receives a Civil Rights complaint from the complainant (e.g., parent) (continued). School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP If the complainant is willing to try to resolve the issue with the sponsor and a satisfactory resolution is achieved, then the sponsor should still remind the complainant (using the information in 1)b)) of his/her right to file at the Federal level if necessary. (*Note: Complainants retain the right to file at the Federal level even if a resolution seems to have been reached at the sponsor level.) The sponsor needs to document the complaint and actions taken (i.e. how resolution was achieved) in a log that is separate from any other complaint log, and notify the State agency of the resolution. Marketing School Meals Put Course Name Here Put Course Name Here d) If the complainant wishes to file at the Federal level, the sponsor should document as much information as possible in their Civil Rights complaint log including, but not limited to, the following: Date Complaint Received Complainant s Name Complainant s Address Complainant s Telephone Number Complainant s Email Address Allegation of Discrimination/Issue (i.e. FNS program involved, protected class(es) involved, etc.) H H H H H H H H H H H H Continued on next slide. 15

16. T TOPIC OPIC 4 | C 4 | COMPLAINTS OMPLAINTSOF OF C CIVIL IVIL R RIGHTS IGHTS D DISCRIMINATION ISCRIMINATION, P , PAGE AGE 4 4 Complaints of Civil Rights Discrimination Procedure for FNS Civil Rights Complaints, PDE, DFN.: 1. Sponsor receives a Civil Rights complaint from the complainant (e.g., parent). School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox d) If the complainant wishes to file at the Federal level, the sponsor should document as much information as possible in their Civil Rights complaint log including, but not limited to, the following (continued): Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Date of Alleged Discriminatory Action 1) The sponsor must forward the information, within 5 days of receipt of complaint from complainant, to the State agency (process depicted below): 2) *State agency level must forward complaint information, within 5 days of receipt of complaint from sponsor, to the FNS regional office. 3) FNS team conducts complaint review and investigation, which includes contact with the complainant, State agency, sponsor, etc. H H H H H H H H H H H H Continued on next slide. 16

17. T TOPIC OPIC 4 | C 4 | COMPLAINTS OMPLAINTSOF OF C CIVIL IVIL R RIGHTS IGHTS D DISCRIMINATION ISCRIMINATION, P , PAGE AGE 4 4 Complaints of Civil Rights Discrimination Procedure for FNS Civil Rights Complaints, PDE, DFN. (continued): 2. Additional Information: School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox a) Complainants must file within 180 days of the alleged action Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here b) Confidentiality is extremely important c) USDA complaint form: https://www.usda.gov/sites/default/files/documents/USDA-OASCR%20P-Complaint-Form-0508-0002-508- 11-28-17Fax2Mail.pdf H H H H H H H H H H H H 17

18. T TOPIC OPIC 5: R 5: RACIAL ACIALAND AND E ETHNIC THNIC D DATA ATA C COLLECTION OLLECTIONAND AND R REPORTING EPORTING Participants will: 1. Describe how racial and ethnic data is used. 2. State the requirements involved in collecting racial and ethnic data. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Racial and Ethnic Data Collection and Reporting Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Racial and ethnic data collection is mandatory. Data is used to: Determine how effectively FNS programs are reaching potentially eligible people. Identify areas where additional outreach is needed. Assist in the selection of locations for compliance reviews. Complete reports as required. If the SFA finds that disparities or incidents of underrepresentation exist, it will be necessary to investigate the causes and take action to ensure equal opportunity to participate in the program(s). For example, when there are disparities with regard to those individuals who are potentially eligible versus those who participate, data must be maintained for three (3) years, and must be transmitted to FNS as requested. H H H H H H H H H H H H Continued on next slide. 18

19. T TOPIC OPIC 5: R 5: RACIAL ACIALAND AND E ETHNIC THNIC D DATA P PAGE ATA C COLLECTION AGE 2 2 OLLECTIONAND AND R REPORTING EPORTING, , Racial and Ethnic Data Collection and Reporting (continued): SFAs are required to use a Household Application for Free and Reduced Price Meals that collects racial and ethnic data in accordance with FNS policy: School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox 1. Ethnicity (must select one (1) of the following) Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Hispanic or Latino Not Hispanic or Latino 2. Race (may select as many as applicable) American Indian or Alaskan Native Asian Black or African American Native Hawaiian or Other Pacific Islander White H H H H H H H H H H H H Continued on next slide. 19

20. T TOPIC OPIC 5: R 5: RACIAL ACIALAND AND E ETHNIC THNIC D DATA P PAGE ATA C COLLECTION AGE 3 3 OLLECTIONAND AND R REPORTING EPORTING, , Racial and Ethnic Data Collection and Reporting (continued): For SFAs who do not utilize applications for Free and Reduced Price Meals, such as those SFAs who participate in CEP, the SFA must still collect racial and ethnic data. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here All households are encouraged to self-declare their ethnic and racial categories. Families cannotberequired to complete the racial and ethnic information. Children are not to be surveyed; questions must be posted only to parents/guardians. However, because all federal programs are required to collect ethnic and racial information, it should already be available in all public schools. Therefore, if a family does not voluntarily provide race/ethnicity information: H H H H H H H H H H H H 20

21. T TOPIC OPIC 6: L 6: LIMITED IMITED E ENGLISH NGLISH P PROFICIENCY D DISCRIMINATION ISCRIMINATION ROFICIENCYAND AND D DISABILITY ISABILITY Participants will: 1. Describe steps that can be taken to ensure meaningful access to programs and activities by persons with limited English proficiency. 2. State the requirements regarding making accommodations for children with special dietary needs School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Limited English Proficiency (LEP) and Program Access Persons with LEP are individuals who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English because of their national origin. SFAs are required to take reasonable steps to ensure meaningful access to their programs and activities by persons with LEP. Failure to do so could be discrimination on the basis of national origin. How do I ensure meaningful access? Translation of vital documents. Translations of some documents are available on the USDA website, such as the household applications (Family Friendly Household Applications). Additional resources to assist with communicating with LEP families are available at the LEP website www.lep.gov/. Complete reports as required. Provide oral interpretation services (e.g. bilingual staff, telephone interpreter lines). Children should not be used as interpreters, and applicants and participants cannot be asked to bring their own interpreters. Train staff on how to provide LEP populations with meaningful access. SFAs that do not have translation and interpretation services should contact PDE, DFN, for assistance. H H H H H H H H H H H H 21

22. T TOPIC OPIC 6: L 6: LIMITED IMITED E ENGLISH D DISCRIMINATION NGLISH P PROFICIENCY ISCRIMINATION, P ROFICIENCYAND , PAGE AND D DISABILITY ISABILITY AGE 2 2 Disability Discrimination A person with a disability has a physical or mental impairment that substantially limits one (1) or more major life activities, has a record of such an impairment, or is regarded as having such an impairment. Major life activity is defined as functions such as caring for one s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here SFAs must provide reasonable accommodations in policies and practices for children who are unable to eat the school meals because of a disability that restricts the diet. This includes providing special meals at no extra charge. SFAs are required to make substitutions or modifications in school meals for children whose disabilities restrict their diets. SFAs must provide modifications for children on a case-by-case basis when requests are supported by a written statement from a state licensed medical authority. Food allergies, food intolerances, celiac disease, and diabetes are examples of disabilities commonly seen in schools. Special dietary needs and requests related to general health concerns, personal preferences, and moral or religious convictions are not disabilities and are optional for SFAs to made. Meal modifications for non- disability reasons are reimbursable provided that these meals adhere to Program regulations. In Pennsylvania, a state licensed medical authority is a licensed physician, physician assistant (PA), certified registered nurse practitioner (CRNP), or dentist. The Medical Statement does not need to be updated each year unless there are changes. PDE, DFN, recommends that you confirm, on a yearly basis, that the diet order has not changed. H H H H H H H H H H H H Continued on next slide. 22

23. T TOPIC OPIC 6: L 6: LIMITED IMITED E ENGLISH D DISCRIMINATION NGLISH P PROFICIENCY ISCRIMINATION, P ROFICIENCYAND , PAGE AND D DISABILITY ISABILITY AGE 3 3 Disability Discrimination (continued): For additional instructions, including the Medical Plan of Care form that can be used to obtain the required information from the medical authority, please reference PEARS > Applications Tab > Download Forms > Feeding Students with Disabilities and Special Dietary Needs section. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here PDE strongly recommends that you take the School Nutrition Toolbox (SNT) module on Serving Students with Disabilities in School Meals www.schoolnutritiontoolbox.org. H H H H H H H H H H H H 23

24. T TOPIC OPIC 7: C 7: COMPLIANCE OMPLIANCE R REVIEW EVIEW T TECHNIQUES N NONCOMPLIANCE ONCOMPLIANCE ECHNIQUES | R | RESOLUTION ESOLUTIONOF OF Compliance Review Techniques To evaluate civil rights compliance during the Administrative Review, the State agency will ensure that the SFA s procedures, as described in the Off-site Assessment Tool on PEARS, meet civil rights requirements. The Off-site Assessment Tool questions on civil rights include: School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here What is the non-discrimination statement that is used for appropriate Program materials? What services does the SFA provide to households comprised of persons with Limited English Proficiency (LEP)? What is the SFA s procedure for receiving and processing complaints alleging discrimination within FNS School Meal Programs? If procedures are written, provide a copy. Has the SFA received any written or verbal complaints alleging discrimination in FNS Programs in the current or prior school year? When was the SFA s most recent civil rights training for staff who interact with program applicants or participants (e.g., cafeteria staff, F/R application approval staff) and their supervisors? Who attended these trainings? What topics were covered by the training? Provide supporting documentation for the responses. How does the SFA collect racial/ethnic data? How often is this information collected? Provide documentation to support the response. Did the School Food Authority publish a public release as required for the School Year being reviewed? What procedures are in place for accommodating students with disabilities? H H H H H H H H H H H H 24

25. T TOPIC OPIC 7: C 7: COMPLIANCE OMPLIANCE R REVIEW N NONCOMPLIANCE EVIEW T TECHNIQUES ONCOMPLIANCE, P ECHNIQUES | R , PAGE | RESOLUTION ESOLUTIONOF OF AGE 2 2 Conflict Resolution and Customer Service Adhere to your SFA s guidelines on conflict resolution. Provide clear information to participants of the SNP, including their right to appeal eligibility decisions. Ensure that staff receives training on best practices in customer service: School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Treat everyone with respect and dignity. Promptly respond to concerns and requests. Approach difficult/tense situations with a calm tone. Avoid casual comments involving race, color, national origin, sex, age, disability, and reprisal. Provide complete and written explanations on eligibility (especially if adverse action is anticipated). Adopt exceptional customer service. H H H H H H H H H H H H 25

26. T TOPIC OPIC 8: M 8: MORE ORE I INFORMATION NFORMATIONAND AND R REFERENCES EFERENCES Information For more information on Civil Rights and Food Nutrition Services, visit the following USDA websites: www.fns.usda.gov/civil-rights School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP www.usda.gov/non-discrimination-statement Marketing School Meals Put Course Name Here Put Course Name Here Pennsylvania Department of Education, Division of Food and Nutrition: Jennifer Jarrett, Manager, School Nutrition Programs, jejarrett@pa.gov or 1-800-331-0129. Civil Rights Law, Policy, and Regulations References Civil Rights Instruction 113-1, provides guidance and direction to the USDA FNS and its recipients and customers, and ensures compliance with and enforcement of the prohibition against discrimination in all FNS nutrition programs and activities, whether federally funded in whole or not. Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, and national origin in programs and activities receiving federal financial assistance; and USDA Implementing Regulation, 7 CFR Part 15, Subpart A and Subpart C. Americans with Disabilities Act (28 CFR Part 35, Title II, Subtitle A), Section 504 of the Rehabilitation Act of 1973 prohibit discrimination based on disability; and USDA Implementing Regulation, 7 CFR Part 15 b. Title IX of the Education Amendments of 1972 (20 U.S.C. 1681 et. seq.), which prohibits discrimination based on sex under any education program or activity receiving federal financial assistance; and USDA Implementing Regulation, 7 CFR Part 15 a. H H H H H H H H H H H H Continued on next slide. 26

27. T TOPIC OPIC 8: M 8: MORE ORE I INFORMATION NFORMATIONAND AND R REFERENCES EFERENCES, P , PAGE AGE 2 2 Civil Rights Law, Policy, and Regulations References (continued): Age Discrimination Act of 1975 (45 CFR Part 91) prohibits discrimination based on age in programs or activities receiving federal financial assistance. Civil Rights Restoration Act of 1987 clarifies the intent of Congress as it relates to the scope of Title VI of the Civil Rights Act of 1964 and related nondiscrimination statutes to ensure nondiscrimination in all programs and activities of a recipient. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Civil Rights in the SNP Marketing School Meals Put Course Name Here Put Course Name Here Enforcement of Title VI of the Civil Rights Act of 1964 National Origin Discrimination Against Persons with Limited English Proficiency, 65 F.R. 50123, August 16, 2000, improves access to service for persons with LEP; and Executive Order 13166. whether those programs and activities are federally funded or not. USDA Departmental Regulation 4330-2, ensures compliance with and enforcement of the prohibition against discrimination in programs and activities funded in whole or in part by the USDA. H H H H H H H H H H H H 27

28. School Nutrition Toolbox Civil Rights in the SNP H H H H H H 28