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Civil Rights Compliance Resources

The National Institute of Food and Agriculture (NIFA) conducts regular, systematic civil rights compliance inspections as required by USDA and the Department of Justice civil rights regulations. These reviews are necessary to ensure that Extension is working in compliance with equal opportunity policies in the implementation of Extension programs, that every customer is treated with fairness, equality and respect, and that we are inclusive and have adequate diversity. The comprehensive reviews, conducted by a USDA Civil Rights Specialist, focus on: administration, program development, program delivery, employment practices and the application of civil rights laws.

The resources below are designed to (a) help K-State Research and Extension prepare for these reviews and (b) ensure that we are genuinely working to provide services to our communities without regard for race, color, national origin, sex, gender, gender identity, religion, age, height, weight, disability, political beliefs, sexual orientation, marital status, family status, or veteran status.

Public Notification of Civil Rights 

One of the basic tenants of Extension work is that we do not discriminate.  Not only is discrimination against the law, it goes against our K-State Research and Extension core values.

One of our civil rights responsibilities is to communicate that we don’t discriminate. We do this in two ways. The first is by displaying the "And Justice for All" poster:  

And Justice for All 

The "And Justice for All" poster must be displayed in every K-State Research and Extension office location, as well as wherever (and whenever) KSRE programming is delivered. In addition to hard copy posters, electronic copies of "And Justice for All" posters can be used when conducting programs using PowerPoint presentations.

  • Hard copies of "And Justice for All" posters can be obtained by contacting Mary Gatza at (785) 532-5790

The second way we communicate that we do not discriminate is by putting our notice of non-discrimination on all of our publications:

Notices of Non-Discrimination

For letterhead, most brochures, posters and other marketing materials, the following statement must be used:


Kansas State University Agricultural Experiment Station and Cooperative Extension Service

K-State Research and Extension is an equal opportunity provider and employer.


For materials related to events – flyers, event invitations, save the dates, etc. the following statement must be used:

K-State Research and Extension is committed to providing equal opportunity for participation in all programs, services and activities. Accommodations for persons with disabilities may be requested by contacting the event contact (insert name) two weeks prior to the start of the event (insert deadline date) at (insert phone number and email). Requests received after this date will be honored when it is feasible to do so.

Kansas State University Agricultural Experiment Station and Cooperative Extension Service

K-State Research and Extension is an equal opportunity provider and employer.


For publications, fact sheets and other numbered publications, the following statement must be used:

Publications from Kansas State University are available at www.ksre.ksu.edu

Publications are reviewed or revised annually by appropriate faculty to reflect current research and practice. Date shown is that of publication or last revision. Contents of this publication may be freely reproduced for educational purposes. All other rights reserved. In each case, credit the authors, Publication Title, Kansas State University, Month Year.

Kansas State University Agricultural Experiment Station and Cooperative Extension Service

K-State Research and Extension is an equal opportunity provider and employer. Issued in furtherance of Cooperative Extension work, acts of May 8 and June 30, 1914, in cooperation with the U.S. Department of Agriculture, Director of K-State Research and Extension, Kansas State University, County Extension Councils, Extension Districts.

Updated May, 2020


View a PDF of these Notices of Non-Discrimination with Spanish Translations  pdf

View the Digital Media Guide for Statements of Non-Discrimination  pdf

In addition to communicating that we do not discriminate, Extension staff must also ensure that partner agencies do not engage in discrimination:

Local Partner Certification of Non-Discrimination

All local unit offices must provide partner agencies with written notification of non-discrimination and ask that they return a signed assurance of non-discrimination. Local partners are any clubs, groups and organizations with which local unit offices cooperate with on an on-going basis.  These include but are not limited to 4-H clubs, Master Gardener groups, livestock producer groups, libraries, PRIDE groups, schools, senior centers, and non-profits.

Notification should state that K-State Research and Extension cannot provide assistance to any organization that excludes any person from membership or participation in any activities of the organization, or subject any person to discrimination because of race, color, religion, national origin, sex, age or disability.

There should be on file:

  1. Copies of this written notification from the local unit office to any club, group or organization with which local units offices cooperate on an on-going basis. 
  2. Written responses from all organizations being served on a continuing basis stating whether or not that organization's policies or practices conform with conditions stated in the notification.

Written notification and collection of assurance of non-discrimination should be repeated every four years.  Certification of non-discrimination from partner organizations should be kept in the local unit civil rights files.  

  • Example of a Written Notification of Civil Rights for local partners  pdf icon
  • General Template of Written Notification of Civil Rights for local partners word icon
  • Spanish Template for Written Notification of Civil Rights for local partners word icon

Parity in K-State Research and Extension 

 What is Parity?

Parity is a relevant measure of how well Extension is meeting the federally mandated requirement of serving all Kansans without discrimination.

Programs are considered to be in parity when the percentage of each racial/gender/ethnic category in our client contacts (program participants) is within 80 percent of the percent of that category in the potential clientele group (local population). For example: if the potential audience for an Extension program is 80% white and 20% Native American, and the actual face to face contacts for that program are 90% white and 10% Native American, then the program is not in parity with respect to Native Americans.

In order to determine if our programs are in parity, we must first know who the potential clientele are. This information can come from several sources. The US Census is a good starting place, but we may also need to look at more specific community data sets such as the Census of Agriculture.

As we know our potential clientele, we should also know our actual contacts. Over the past few months many have questioned the need to report quarterly client contacts. Reporting is a key element of civil rights compliance. Reporting client contacts not only helps us to quantify the reach of our Extension programs, but reporting the demographics of those we serve helps us to know if we are achieving parity.

When we have not achieved parity in program participants we must demonstrate (and document) “all reasonable efforts” we have implemented to attempt to achieve parity.

Compliance Reviews 

The National Institute of Food and Agriculture, and its land-grant partners, such as K-State Research and Extension, are committed to being equal opportunity providers of extension programs. These programs must treat every customer and employee with fairness, equality, and respect. This applies to all aspects of the program including identifying needs, setting priorities, allocating resources, selecting and assigning staff, conducting programs, and getting feedback.

The performance of a civil rights audit and review is one of the major and unique requirements of federal civil rights legislation. It provides a systematic process for the assessment of compliance with federal regulations as it pertains to policies, procedures, programs, and practices as well as the development and implementation of modifications to correct any instances where deficiencies are identified.

K-State Research and Extension Resources 

 

Policy and Procedures

As an integral part of a Land-Grant university that receives funds from USDA through the National Institute of Food and Agriculture (NIFA), K-State Research and Extension is committed to fair and equitable treatment of all employees and program participants. In fact, as the nation’s oldest Land-Grant institution, K-State has been putting service and compassion into action since 1863. The university was only the second public institution of higher learning in the U.S. to admit women and men equally. Throughout history, the university has remained committed to creating a level playing field where all can succeed and overcome challenges.

K-State Research and Extension also believes in the principles of diversity, equity and inclusion because we know that human differences enrich our lives, work and communities. We embrace our responsibility to be a resource for all, regardless of their cultural, ethnic or economic background.

While there are clear distinctions between compliance concepts and diversity concepts, the two are intertwined. Our actions as Extension professionals should reflect our organizational beliefs. What is expected of us and the mechanisms used to demonstrate those actions are known as civil rights compliance.

Below, you can find information about Policies and Procedures related to civil rights compliance that must be followed to ensure we remain a resource for all members of our communities.

Policy

Federal Legislation 

The Civil Rights Act of 1964; Title VI

  • Ensures access to Federally funded programming/assistance
  • Prohibits discrimination on the basis of race, color, and national origin

The Civil Rights Act of 1964; Title VII

  • Outlaws Employment Discrimination
  • Prohibits discrimination based on race, color, religion, sex, and national origin
  • Created the Commission on Equal Employment Opportunity

The Age Discrimination in Employment Act of 1967

  • Outlaws discrimination on the basis of age in the workplace
  • Focuses on persons age 40 and older

Education Amendments of 1972; Title IX

  • Bans Sex Discrimination 
  • Focused on educational programming

Rehabilitation Act of 1973; Sections 501 and 505

  • Prohibits Disability Discrimination in federal employment
  • Governing remedies for disability discrimination

Americans with Disabilities Act (ADA) of 1990; Titles I and V

  • Bans discrimination against those with physical or mental disabilities
  • Focused on "all aspects of society"
  • Compensatory and punitive damages for victims of disability discrimination 

Americans with Disabilities Act (ADA) Amendments Act of 2008

  • Clarifies and broadens the Americans with Disabilities Act of 1990 

 The Civil Rights Act of 1991; Title I

  • Compensatory and punitive damages for victims of discrimination
  • Mandates reasonable accommodations and good faith efforts to avoid discrimination

Limited English Proficiency Initiative of 2000; Executive Order 13166

  • Requires that federal agencies develop and implement systems to provide their services so that Limited English Proficiency persons can have meaningful access to them

 

Abridged list of Federal Civil Rights for K-State Research and Extension offices  pdf

Americans with Disabilities Act (ADA) Guide for State and Local Governments

USDA and ECOP Policies 

United States Department of Agriculture (USDA)

Cooperative Extension

State Policies 

Kansas State University Policies 

K-State Research and Extension Policies 

 

Our All Reasonable Efforts Policy 

The intent of the Civil Rights Act is that all people have the opportunity to participate in educational programs and employment opportunities in federally assisted programs.  This intent and the means for achieving it are consistent with the Extension philosophy that its programs are open to all persons and that those programs will be designed to best meet their needs.

A sincere effort must be made to encourage participation by minority members and to overcome barriers and concerns that might interfere. It is not enough to simply announce the program is open to all. An effort must be made to tailor the program to meet the needs and concerns of the target audience.

Examples of barriers to participation include means of publication, location of meetings, etc., not normally used by the target
audience.

The minimum reasonable effort required by Extension staff include three steps:

  1. Use of all available mass media, including websites, radio, newspaper, and television, to inform potential recipients of the program and of the opportunity to participate.
  2. Personal letters addressed to defined potential recipients inviting them to participate, including dates and places of meetings or other planned activities.
  3. Personal visits by the Extension staff member(s) to a representative number of defined potential recipients in the geographically defined area to encourage participation.

Documentation is needed that"All Reasonable Efforts" have been made. Copies of mass media releases and circular letters meet requirements for 1 and 2 above. Personal visits may be documented by making a record for filing of personal visits including visitor, dates, person reached, responses and other related information. 

 

Local Partner Certification of Non-Discrimination 

All local unit offices must provide partner agencies with written notification of non-discrimination and ask that they return a signed assurance of non-discrimination. Local partners are any clubs, groups and organizations with which local unit offices cooperate with on an on-going basis.  These include but are not limited to 4-H clubs, Master Gardener groups, livestock producer groups, libraries, PRIDE groups, schools, senior centers, and non-profits.

Notification should state that K-State Research and Extension cannot provide assistance to any organization that excludes any person from membership or participation in any activities of the organization, or subject any person to discrimination because of race, color, religion, national origin, sex, age or disability.

There should be on file:

  1. Copies of this written notification from the local unit office to any club, group or organization with which local units offices cooperate on an on-going basis. 
  2. Written responses from all organizations being served on a continuing basis stating whether or not that organization's policies or practices conform with conditions stated in the notification.

Written notification and collection of assurance of non-discrimination should be repeated every four years.  Certification of non-discrimination from partner organizations should be kept in the local unit civil rights files.  

Limited English Proficiency 

As an agency that receives federal funds, K-State Research and Extension is obligated to take reasonable steps to ensure that those with Limited English Proficiency (LEP) have meaningful access to our programs, services and information.  Limited English Proficiency refers to persons who do not speak English as their primary language and/or who have limited ability to read, write, speak or understand English. 

K-State Research and Extension has certain legal obligations to ensure nondiscrimination for LEP persons.

  • Requests for language support services--KSRE has a legal obligation to provide accommodations for individuals with limited English proficiency. Therefore, it is unlawful to deny a request for language support services to a person who is a participant, or wants to participate in KSRE programs, services, and activities.
  • Requests made by members of the public—KSRE is legally obligated to provide translation or interpretation services any time a member of the public requests services in connection to their—or someone else’s—restricted ability to access or understand English-only information that is related to our educational programming activities.
  • Programming that requires critical or vital communication--Critical or vital communication means information in any format that clientele/participants need to access programming. Any English-only document used by KSRE in an official capacity is subject to translation. This is particularly true for applicant participation, release or consent forms, documents related to a participant’s medical history, emergency information, and other documents that ask for information that is sensitive in nature.
  • General educational programming--KSRE may be legally obligated per Title VI to provide language support services in educational programming based on, among other things, 1) the nature and scope of the project, 2) the target audience, and 3) community demographics within the designated service area.

Local units should access the number or proportion of limited English speakers in the local population to determine whether or not a local language services plan needs to be developed.

Disability and Title IX protections in K-State Research and Extension  pdf

K-State Research and Extension's Plan for Public Notification of Civil Rights  pdf

K-State Research and Extension's Civil Rights Performance Plan  pdf

K-State Research and Extension's Mailing List Policy PDF

Procedures

Complaints 

Program participants have a right to complain if they feel they have been denied access to extension programming. Each extension staff member should know the proper procedure for handling a complaint:  

Responding to Discrimination Complaints

 Resources Regarding Discrimination Complaints

Filing Civil Rights Information