How to Prepare for an Internal Program Assessment

NIFA AGNR Civil Rights Compliance Review Timeline

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Scope of Authority

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In accordance with United States Department of Agriculture civil rights regulations 7 CFR 15 any recipient of federal financial assistance, regardless of the amount, is subject to civil rights reviews. Further, the primary recipient of federal financial assistance is responsible for civil rights administration where the primary recipient has extended the financial assistance to another recipient. 

7 CFR Subpart A - Nondiscrimination in Federally-Assisted Programs of the Department of Agriculture - Effectuation of Title VI of the Civil Rights Act of 1964

Part 15 - Nondiscrimination (§§ 15.1 - 15.143)

Part 15a - Education Programs or Activities receiving or benefitting from Federal financial assistance (§§ 15a.100 - 15a.605)

Part 15b - Nondiscrimination on the Basis of Handicap in programs or activities receiving Federal financial assistance (§§ 15b.1 - 15b.42)

Part 15c - Nondiscrimination on the Basis of Age in programs or activities receiving Federal financial assistance from the United States Department of Agriculture (§§ 15c.1 - 15c.10)

Part 15d - Nondiscrimination in programs or activities conducted by the United States Department of Agriculture (§§ 15d.1 - 15d.5)

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Document and Data Request from Sister Land-Grant Universities

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Preparing for our Civil Rights Review��

• An opportunity to collectively and individually highlight our work, lessons learned and areas of growth;
• Review and update your Civil Rights related files;
• Review how our Civil Rights mandates are reflected/actualized in your planning, evaluation and reporting processes;
• Review Civil Rights Laws and Policies;
• Establish best practices and a strategic path-forward; and
• Prevent practices that are not aligned with our mission.

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Civil Rights Compliance

As a means to help ensure Civil Rights Compliance, we should be guided by the following key elements, Extension…

must not discriminate – in employment, in programs, in providing services (AS/EEO/RA statements);

does not provide services to, or work in concert with, agencies or organizations that engage in discrimination (partner letters – Assurance Agreement);

collects data in an effort to identify and diversify program participants (demographic collection/needs analysis/data analysis);

has a responsibility to inform the public of these policies, programs and services

(Assurance Agreement /AS/EEO/RA statements/Language Access); and

proactively plans and implements its plans to meet compliance obligations

regularly evaluate their success (POW/ UMERS/program complaints).

1. Organizational Capacity

• Index and File Maintenance document.
• Updated organizational charts with position description and must display a revision date.
• The current Civil Rights point of contact name must appear on all organizational charts.
• Copies of Agenda for staff meeting and/or conferences attended by UME extension faculty/staff for the past two years which include civil rights related updates and/or topics.

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2023 will be crucial to showcase conversations surrounding c/r.

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3. Advisory Boards & Committees

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As noted in Federal civil rights regulations, 28 CFR Ch. 1 §42.104 (b) and 7 CFR 15 Subpart A, 15.3 (b), (vii), “A recipient to which this subpart applies may not discriminate on the grounds of race, color, or national origin… deny a person the opportunity to participate as a member of a planning or advisory body which is an integral part of the program.”

Advisory Boards & Committees Continued…

Develop/implement a centralized recruitment strategy to ensure board demographics reflect service populations, specifically, underserved, underrepresented and socially disadvantaged groups.

Develop a consistent and centralized method to collect advisory board REG data.

Copies of any and all data from committees, written solicitation, selection, and recruitment procedures/criteria for positions on all internal and external extension-related advisory committees and boards.

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4. Data Collection & Integrity

Develop a consistent and centralized method to collect REG data from program participants (Data Collection Policy).

Registration data is regularly compared against Census data for reliability and to ensure that all are provided an equal opportunity. What are you using and is it effective?

Census data (Dashboard), UMERS Summary Parity Report, Invitation to Self-Identify for county sponsored events (individual and aggregate), and official Census Race definitions.

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Let’s discuss notable opportunities

How did you hear about us?

Are you interested in volunteering?

Do you want to sign up for our mailing list?

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Data Collection & Integrity Continued…

Demographics Presentation:

• The presentation should draw on census data as well as data and information from local formal sources.
• The presentation will include the following information: race, ethnicity, SEX (gender), age (youth or adult – effective January 1, 2023), disability, veterans, language (effective January 1, 2024), and differences (other grant sponsored characteristics) by geographic area/program specific )county and city parameters.

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Assessments and Analysis:

Barrier Analysis – How am I programming?

Parity Analysis - +/-5%

4 Factor Analysis (LEP)

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Data Collection & Integrity Continued…

Barrier analysis identifies:

• Barriers that underserved communities and individuals may face to enrollment in and access to benefits and services in Federally funded programs;
• Barriers that underserved communities and individuals may face in participation in grant programs and other forms of financial assistance;
• Opportunities in current policies, regulations, and guidance to address affirmatively and equitably the underlying causes of systemic inequities in society;
• Individual biases and resistant to change; and
• Resources.

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Parity Analysis:

• Parity measures the relative level of inclusion of the available population in Extension programs. UME is adopting a new method for calculating parity to assess its relative success in outreach to the population.
• UME Extension faculty and staff have a legal obligation to collect data on program participants.
• Program delivery faculty and staff are to separate the collection of personal information like names and contact information from the demographic data reported in UMERS.
• Program participants should be asked to provide ethnicity, race, and sex separately and dependent on collection - anonymously.

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Parity vs Equity Resource

Parity +/- 5%; The legal parity percent distribution of program participants is +/- 5 as approved in the AGNR Affirmative Action Plan

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5. Non-Discrimination Based on Sex

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• USM Policy on Professional Conduct and Workplace Bullying VII-8.05
• UMD Equal Employment Opportunity and Affirmative Action Statement of Policy VI-1.00 (A)
• UMD Nondiscrimination Policy and Procedures VI-1.00 (B)
• UMD Policy on Threatening and Intimidating Conduct VI-100 (F)
• UMD Policy and Procedures on Sexual Harassment and Other Sexual Misconduct VI-1.60 (A)

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"No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.”

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Reminder: NOVEMBER 30, 2023 – TITLE IX AND RESPONSIBLE UNIVERSITY EMPLOYEE TRAINING…

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Anti-Harassment Procedure

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6. Public Notification

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Public Notification Continued…

• Public Notification Procedure, Social Media Policy, AGNR DEIR, LEP (draft), AAP (draft).
• Mailing List Log is included in this file documents which is comprised of newspaper clippings, newsletters, social media, brochures, etc.
• And Justice for All posters and LEP posters posted in conspicuous areas (Green posters for offices; Blue posters for Snap-ED program).
• Copies of any and all marketing materials for events organized or hosted by UME extension program. Such materials may include, but not necessarily be limited to: Materials related to public notification plans and procedures; Outreach materials designed to increase participation in extension-related events; official nondiscrimination policy statement used on printed publications/emails. Announcements for extension listening lessons, programs, or other educational events open to the general public or college community as a whole.

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�Benefits and Services offered

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No person in the United States shall, on the ground of Race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity of the applicant or recipient in accordance with 7 CFR 15.3. Subpart A, (d), (10), (i), (ii) and (iii).

7. Accessibility For Individuals with �Disabilities

Accommodation Statement

Accessibility Assessment for UME & MAES Facilities Checklist to show that no existing barriers for people of all abilities

Request form for those who require a reasonable accommodation

Copies of information relating to accessibility for individuals with disabilities, to include:

Name of person(s) responsible for ensuring programs are fully accessible;

Steps taken to eliminate barriers and make programs and facilities more accessible;

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In accordance with 7 CFR15b.17, no qualified handicapped person shall, because a recipient's facilities are inaccessible to or unusable by handicapped persons, be denied the benefits of, be excluded from participation in, or otherwise be subjected to discrimination under any program or activity receiving assistance from this  Department.

8. Language Access

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Language Continued…

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NIFA issued Limited English Proficiency (LEP) guidance on April 12, 2016 to Land-Grant Universities and other partners. Such guidance was to effectuate provision of USDA regulation 7 CFR 15b Subpart A, § 15.3 (a) and such compliance as required by recipients of Federal financial assistance.

Language Continued… Effective January 1, 2024

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9. Partnerships with 1890 Partners, Sister Land Grant Institutions and other Colleges and Universities

Memorandum of Understanding with 1890 Partners, Sister Land Grant Institutions and other Colleges and Universities.

Partnerships and interactions with 1890/ Land-Grant Institutions (i.e. mailings, correspondence, etc.).

Copies of any and all written Assurance Agreement with Partnering Organizations UME extension partners and/or subrecipients.

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25% or more HSI

10. Compliance Requirements

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CR Training 6/7/9

ADA Review of Facilities

Assurance Statements

Confirming Accessibility to Programs and Locations

Public notification Social Media, Web, Marketing, various Communication Strategies

Language, Vets, Disability, etc

Data, Parity and Census

Compliance Resources

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Procedure for processing program and employment discrimination complaints �

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• Complaint receipts and dispositions, including any current complaints.
• Names of contact person for the office handling complaints.
• Verify the use and display of the “…And Justice for All” poster.
• Was information provided on marketing material (EOP/RA).
• Updated Assurance Agreements.

11. (Extension) Program Outreach/Delivery

UME Data Collection Policy, Participant Contact Sheet, and UMERS County Level Program Summary Printout.

REG data collected for Participation in the following Program Categories: 4-H and Youth Development, Garden, Agriculture, Natural Resources, Food, Health, Nutrition, and Family, Community and Economic Development.

Provide plans and policies for program participation data and information collection in UME extension, including screen shots of the system used for participant data collection.

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What inclusion really means…

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Tips for Maintaining Civil Rights File and Data

Request and record demographic data (race, ethnicity, gender (REG) and age) from participants reached at events.

Create an online location/or hard files for storing emails you send or receive that provide evidence on collaborations, efforts to build relationships and establish partnerships to reach and serve protected audiences. Place printed copies of most relevant emails in the appropriate hard-copy folder. – Cannot locate or access is inexcusable….

Create files for the protected and underserved audiences you are intentionally reaching and making efforts toward serving. Keep communication and documents used for your efforts in these files throughout the year. Youth data stored under lock and key/usually not with adult data. Recommend purging records over 5 years old.

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2023 IPA Scheduled Reviews and Trainings

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Prior Training which has occurred…. Do you remember

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AGNR Office of Human Resources Management and Compliance Programs

1119 Symons Hall

301-405-2935/agnrhrmcp@umd.edu