Civil Rights Training

Colorado WIC Staff

About this Training

Everyone working in the WIC Program is required to receive annual training on Civil Rights.

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A complete list of policies and procedures related to Notification, Civil Rights, and Fair Hearings is available in the Colorado WIC Policy and Procedure Manual, Section 11: Civil Rights

Learning objectives

After reading this material, you will be able to:

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• Demonstrate at least 2 ways to prevent Civil Rights discrimination complaints.
• Recall the process for filing Civil Rights discrimination complaints.
• Explain why WIC collects race and ethnicity data.

WIC Civil Rights Requirements are to:

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• Provide other language services for people with limited English proficiency (LEP).
• Resolve conflicts.
• Provide good customer service.

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Civil Rights are the rights of individuals to be treated equally.

USDA Civil Rights: Protected Groups

WIC must treat everyone fairly. Staff may not discriminate against anyone based on:

• Race
• Age
• Color
• Sex
• National Origin
• Disability

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• Religion
• Marital Status
• Family/Parental Status
• Political Beliefs
• Limited English Proficiency
• Source of income, such as income from a public assistance program

About discrimination

Discrimination occurs when individuals are:

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• Denied services unfairly
• Delayed from receiving services
• Treated differently from others

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Because of the person’s race, color, national origin, sex, age, disability, religion, limited English proficiency, marital status, familial status, political beliefs, or source of income (i.e., public assistance).

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Tips for preventing Civil Rights violations

7 tips to help prevent violations:

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Tip #1

Provide good customer service to every applicant and participant. Treat all participants equally.

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Tips for preventing Civil Rights violations

Tip #2

Ask questions & check for understanding.

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• Prevent miscommunication by asking questions and checking for understanding.
• Don’t assume you know.
• It’s better to be sure you correctly understand a person’s question or response than to fill in the missing pieces.

Tips for preventing Civil Rights violations

Tip #3

Let the person know what to provide for their WIC appointment.

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• While this information is provided in a reminder text message, it's good customer service when speaking with a client and scheduling the appointment to tell them so they can ask questions and get additional information.

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• This can help prevent any delay of services.

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Tips for preventing Civil Rights violations

Tip #4

Help participants understand WIC.

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• Help applicants and participants learn about the WIC program, so they know what to expect.
• This includes information about how to apply for WIC.
• How to follow WIC rules by going over the Rights and Responsibilities
• Explaining what to expect from the program.

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Make sure they know:

• Income eligibility requirements.
• When their eligibility ends.
• WIC Rights & Responsibilities.

Tips for preventing Civil Rights violations

Tip #5

Inform applicants and participants about appointment times or expected wait times if in the clinic.

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This is good customer service.

It lets everyone know that the time scheduled to provide WIC services is similar for all applicants and participants.

Tips for preventing Civil Rights violations

Tip #6

Follow processing standards.

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• Pregnant and migrant applicants must be offered an appointment within 10 days of their initial contact with WIC requesting program services.
• Applicants in other categories (children, infants, postpartum and breastfeeding women) must be offered an appointment within 20 days of their initial contact with WIC requesting program services.

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Tips for preventing Civil Rights violations

Tip #7

Make sure transfer participants don’t miss out on WIC benefits.

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• Ensure that participants transferring into your clinic receive uninterrupted benefits, so they don’t miss out on any WIC benefits they’re entitled to receive. Including eligibility for breast pumps.

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Remember…

The goal is to ensure that participants and applicants are not unfairly denied services, delayed in receiving services, or treated differently due to their:

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• Race
• Color
• National origin
• Sex
• Age
• Disability

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• Religion
• Marital Status
• Family/Parental Status
• Political Beliefs
• Limited English Proficiency
• Source of income, such as income from a public assistance program

Access for Limited English Proficiency (LEP) Participants

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Local agencies must ensure that interpretive services are available for participants with limited English proficiency. This is done by:

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• Employing bilingual staff who speak the language of the clients served,
• Using qualified interpreters, and/or
• Using your agency or state office provided phone interpretation service.

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WIC should not require participants provide their own translator.

Reasonable Accommodation

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WIC clinics and services must be accessible to people with disabilities. Local agencies must make reasonable accommodations for applicants and participants with disabilities.

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•Websites and online information systems must be accessible and usable by persons with visual impairment and other disabilities.

•Buildings should be accessible to people with disabilities. If structural changes to buildings aren’t possible, program access can be provided through other methods.

• Offer services and benefits remotely (following policy & procedure).

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Public Notification

The purpose of public notification is to ensure that individuals, including those in underserved populations and local organizations, are aware of program availability.

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Program Availability

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•Inform applicants, participants, and potentially eligible persons of their program rights and responsibilities and the steps necessary for participation.

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Complaint Information

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•Advise applicants and participants of their right to file a complaint, how to file a complaint, and the complaint procedures.

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Nondiscrimination Statement

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•All information materials and sources used to inform the public about WIC must contain the nondiscrimination statement.

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Public Notification

“And Justice For” All Poster

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All clinics must display the “And Justice For All” poster in a place viewable by participants such as in the waiting room.

• It explains WIC’s non-discrimination policy.
• It notifies people of steps they can take if they’ve been discriminated against by WIC.

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For more information about the poster visit And Justice for All Poster, Got One?.

Public Notification

Non-Discrimination Statement

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• Any material that includes information about WIC must include the non-discrimination statement.
• When space is limited and the entire statement can’t be included, the shorter version, “This institution is an equal opportunity provider,” may be used.

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• The non-discrimination statement is not required to be imprinted on items such as cups, buttons, magnets and pens that identify the WIC Program, nor on nutrition education and breastfeeding promotion materials that provide a nutrition message but not provide program information or requirements.

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WIC is required to notify applicants and participants that WIC doesn’t discriminate.

Public Notification

Rights and Responsibilities (R&R)

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• Must be provided to applicants/participants at certification and recertification.
• Explains the basic rights of WIC participants and their responsibilities.
• Must be read by or read to the participant/endorser in a language they understand.
• Participant/endorser’s signature or verbal acknowledgement indicates they read, understand and agree with the R & R.

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The R&R includes the nondiscrimination statement and information on how to file a complaint.

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Civil Rights Discrimination Complaints

Despite your best efforts at customer service and at following the rules, some individuals may feel that they have been subjected to discrimination.

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• Everyone has the right to file a discrimination complaint.
• All staff must know how to process Civil Rights complaints.
• Any individual alleging discrimination based on race, color, national origin, age, sex, disability, religion, limited English proficiency, marital status, familial status, political beliefs, or source of income (i.e., public assistance) has the right to file a complaint.

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How Participants File a Complaint

• Complainants may submit their complaint directly to the USDA Office of Civil Rights, or can ask WIC staff for assistance in filing the complaint.
• You should direct the complainant to complete the USDA Complaint Form found online. Instructions for completing the form electronically, or providing the information in written form are included on the “And Justice for All” poster, the Rights and Responsibilities form and on the USDA website.

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Civil Rights Complaints – Your role

• When you are aware that an applicant or participant would like to file a Civil Rights complaint, you must assist the person in completing the form, if needed.
• All complaints, written or verbal must be accepted, and you must instruct complainants on how to file a complaint. If a verbal complaint is reported and they choose not to put the allegations in writing, you must write up the complaint and submit it to your state nutrition consultant.

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See WIC Policies & Procedures, Section 11, Civil Rights Complaint Processing

Timeframe for Submitting Civil Rights Complaints

When an applicant or participant wants to file a complaint, the person must file the complaint within

180 days of the alleged discriminatory action.

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You are required to notify your state nutrition consultant of the complaint within 2 days of receiving the complaint. Additional guidance will be provided.

The complaint must be submitted to USDA within 5 days of receiving the complaint.

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Confidentiality

Do not share details of complaints with colleagues.

Do not retaliate against anyone for filing a complaint.

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You protect the confidentiality of the applicant or participant by sharing details of the Civil Rights complaint only with the staff member receiving the complaint, the applicant or participant, your supervisor or director, and the state nutrition consultant and Civil Rights coordinator.

DATA Collection Requirements

Participant Race and Ethnicity

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Why does WIC collect race and ethnicity data?

• Racial and ethnic data is used to ensure that the program is accessible to all groups.
• Information is used for statistical purposes only and has no effect on eligibility criteria.
• Agencies should compare their participant data with potentially eligible persons within their service areas. If disparities or areas of under-representation occur, agencies are expected to investigate the causes, and conduct additional outreach as needed.

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Collecting Racial/Ethnic Data

• The preferred method for obtaining information about a participant's race and ethnicity is to ask them to self-identify.

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• If a participant is unable or unwilling to self-identify, document their race and ethnicity based on visual assessment.

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• For remote appointments, use your best judgment to determine race and ethnicity.

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• Race and ethnicity must be documented

in Compass.

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Summary & Next Steps

Discrimination occurs when someone is:

• denied services unfairly,
• delayed from receiving services, or
• treated differently from others,

because of their race, color, national origin, sex, disability, or age.

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To complete this annual training requirement, check your understanding by answering the questions on the knowledge check. Notify your supervisor when you’ve completed the training and the knowledge check. Your supervisor will mark you completion in Compass.