Clientele Group Baseline and Civil Rights Compliance Planning

Daniel Obrist, Vice Provost

David White, Analyst, Office of Civil Rights

Kit Alviz, Analyst, Program Planning & Evaluation

Guest Presenters from Informatics and Geographic Information Systems and UC Master Gardener Program

September 2, 2025 - 10AM-12PM

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Non-Discrimination Statement �

In accordance with all applicable state and federal laws and University policy, the University of California, Agriculture and Natural Resources, does not discriminate on the basis of race, color, national origin, religion, sex, gender identity, pregnancy (including pregnancy, childbirth, and medical conditions related to pregnancy or childbirth), physical or mental disability, age, medical condition (cancer related or genetic characteristics), ancestry, marital status, citizenship, sexual orientation, or service in the uniformed services (includes membership, application for membership, performance of service, application for service, or obligation for service in the

uniformed services), status as a Vietnam-era veteran or special disabled veteran. As required by Title IX, the University of California, Agriculture and Natural Resources, does not discriminate on the basis of sex in its educational programs, admissions, employment, or other activities.

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UC Cooperative Extension program or activity conducted or funded by the U.S. Department of Agriculture (USDA) must comply with all applicable USDA guidance and requirements.

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Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the UC ANR Office of Civil Rights, contacts: EEO Representative David White at 530-786-0206 or email: dewhite@ucanr.edu, or Interim Civil Rights Compliance Officer Tina Jordan at 530-750-1280 or email tljordan@ucanr.edu. Individuals may also contact USDA through the Telecommunications Relay Service at 711 (voice and TTY). Upon request,program information may be made available in languages other than English.

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To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at How to File a Program Discrimination Complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Mail Stop 9410, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov.

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Alternatively, a program discrimination compliant may be filed with the UC Harassment & Discrimination Assistance and Prevention Program (HDAPP) by email at hdapp@ucdavis.edu or via phone at 530-304-3864. Individuals can also contact the UC ANR Title IX Coordinator Wendi Delmendo at wjdelmendo@ucdavis.edu or via phone at (530) 752-9466.

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Agenda

10:00 - Welcome and overview

10:10 - Introduction to civil rights compliance: Lecture and activity

10:35 - Choose Your Own Adventure:

25 minutes on your own then group discussion

11:10 - 5 minute break

11:15 - Using statistics to develop goals: Demo and activity

11:30 - Civil rights compliance goals: Examples and activity

11:45 - Mapping tools for assessing parity and civil rights compliance

11:50 - Open discussion and wrap up

12:00 - Adjourn

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Desired Outcomes

As a result of participating in today’s training, participants will have:

• Understanding of how-to define clientele groups and strategies for collecting baseline data
• Understanding of civil rights compliance goal examples
• Hands on experience using Project Board or Statewide Program data to track annual progress against goals.

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UC ANR Leadership Welcome

• 2025 USDA NIFA Civil Rights Research Compliance Review (Focus: USDA-funded and supported research, federally funded faculty, graduate students); next review (extension) expected in 3-4 years
• USDA NIFA Civil Rights Compliance requirements:
• Today and Thursday’s training: Define clientele, establish baseline, document and report contacts, conduct all reasonable effort.
• Other requirements:
• Notification Requirement: post full USDA nondiscrimination statement on all print and non-print materials (alternatively, use short form: “This institution is an equal opportunity provider.”).
• Notification Requirement: Recipients are required to notify individuals with disabilities and LEP individuals of their right to free accommodations and language assistance.
• “…And Justice for All” Posters: Posters must be “prominently displayed in all offices where there is a USDA presence and where it may be read by customers.”

UC ANR Academic Program Review Dossier Requirements

• Documentation of Civil Rights Compliance in Extension Activities is a legal requirement of your program reporting and should be addressed in this section
• document efforts to define your clientele group baselines
• show evidence of program efforts to reach and serve your defined clientele
• report the efforts you have made to increase equitable opportunities for participation in your program
• Document additional contributions and activities that support ANR’s Principles of Community in personnel or programmatic activities (can be described throughout your dossier, not only in this section).
• https://ucanr.edu/site/division-agriculture-and-natural-resources/principles-community

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Why Do We Have �Civil Rights Laws?

David White, Analyst, Office of Civil Rights

Brief History

Because the journey from . . .

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here . . . to here . . .

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• Is on-going
• Some steps forward, some backward
• But it is on-going

Civil Rights Program Authorities

• Title VI of the Civil Rights of 1964
• Sections 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (ADA), & the ADA Amendments Act of 2008
• Title IX of the Education Amendments of 1972
• Age Discrimination Act of 1975

Civil Rights Program Authorities

• Civil Rights Restoration Act of 1987
• 7 CFR Part 16, “Equal Opportunity for Religious Organizations”
• Executive Order 13166 – “Improving Access to Services for Persons with Limited English Proficiency" (August 11, 2000)
• USDA LEP Policy Guidance (79 Fed. Reg. No. 229, page7077. Friday, November 28, 2014)

Essential Terms

Civil Rights: The rights of individuals to receive equal treatment and to not be denied equal treatment because of the color of their skin or for any other list of characteristics known as the legally protected classes (i.e. age, sexual orientation, nationality, etc.).

Essential Terms

Discrimination: Different treatment which makes a distinction of one person or a group of persons from others; either intentionally, by neglect, or by rude or discourteous treatment, or by other actions or lack of actions based on…

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gender expression,�national origin, �disability, �veteran status, �sexual orientation, �genetic information �

�or any other characteristic �protected by law.

race, �color, �religion, �sex, �gender, �gender identity, �

Essential Terms

• In a given county or program, the potential clientele consists of all those individuals or organizations who have a need for, would benefit from, and who are eligible for participation in any existing or planned educational activity that might be conducted in the fulfillment of the program’s mission. Depending on how the potential clientele is defined, the demographic makeup (i.e. the race, ethnicity, and gender breakdown except for organization clientele groups) of that particular population is derived from the “best” available source(s). This demographic breakdown becomes the baseline for that particular clientele group; it is the population of persons eligible to participate in programs and related activities.

Essential Terms

• Actual participants in the applied research and/or educational programs carried out in the accomplishment of the UCCE program’s mission are the actual clientele contacts.
• New and for implementation by 2026: Advisory committees that are convened by UC ANR employees and include external members are also considered actual clientele contacts.
• The number of contacts (broken down by race, ethnicity, gender, and/or organizational attendees) are documented in Project Board AND enrollees in CE programs are tracked in systems outside of Project Board (i.e. 4-H enrollees, EFNEP participants, Master Gardener or Master Food Preserver participants enrolled by volunteers) are not counted as contacts in Project Board in most cases. (Call the Office of Civil Rights for clarification.)

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Essential Terms

• Targeted clientele are a subgroup of potential clientele and are potential participants in an education program or research project an academic is planning for a specific program year. They may also include a group whose percentage of participation is lagging behind their percentage in the baseline. For example, if Hispanics make up 40% of a clientele group but are only 5% of the actual clientele contacts, Hispanics in that particular clientele group could become a “targeted clientele” for additional all reasonable effort and engagement in an attempt to increase their percentage of participation.

Essential Terms

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• Compliance: A program is in compliance � when parity of participation is � achieved or when outreach efforts demonstrate that an all reasonable effort (ARE) has been exerted to equitably offer the opportunity to participate to all potential clientele (i.e. when the All Reasonable Effort standard has been met, see next slide).

C o m p l i a n c e:

Essential Terms

• Parity: When the percentages of underrepresented rac races and ethnicity in the actual clientele contacts or program participants approach (come to within at least 80%) their percentages in the potential (i.e. the base- line), then parity of participation (or parity) has been achieved.��
• All Reasonable Effort is defined as the� utilization of at least three recommended� outreach methods* to increase opportunities� for program participation.

P A R I T Y :

All Reasonable Effort:

Your Civil Rights Compliance Responsibilities

Civil Rights Reporting and �Data Collection

• Statewide program system s (4-H Enrollment System, PEARS, WEBNEERS, VMS, etc.) and Project Board have civil rights data components. This documentation helps demonstrate that ANR is executing its CE mission with equality – that the “quantity and quality of benefits and services” is the same for both people of color and whites.

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• California courts have held that the collection of racial data to monitor for non-discrimination does NOT violate state law prohibiting the consideration of race, sex, or ethnicity in areas of public employment, public contracting, and public education.

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Statewide program systems

California courts

Your Responsibilities: Identify Your Potential Clientele

• Your PVA & PD should provide key clientele information. Work with your county director and program colleagues to discover additional groups who may also become potential clientele�
• Ask who would be interested in or benefit from your educational program�
• Consider the geographic area of your potential audience/clientele�
• Work with collaborators, agencies and stakeholders who represent and serve groups you are trying to reach.

Your Responsibilities: Establish Your Baseline

• Define potential audience for each program�
• Learn about the demographics of your county by viewing US Census, Ag Census, Ag Commissioners Report, local data, and local knowledge.

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• Office of Civil Rights has Excel spreadsheets of US Census data by county for California – we will update these spreadsheets in Fall ‘26, Fall ‘29, and Fall ‘33, etc.

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Your Responsibilities: Baseline Documentation and Reporting

• Keep of documentation of your baseline for three years, including your sources and copies of either Assurance of Nondiscrimination forms or website statements about nondiscrimination of non-governmental organizations.�
• Academics: Report in Project Board your clientele groups and baseline information. Revise your baseline when new information becomes available. (Statewide Programs utilize Census or CBEDS provided by UC ANR)

Frequently Asked Questions

Is it bad that I am not in parity?

• No. You can achieve compliance by either parity or establishing All Reasonable Effort (A.R.E.). The “Improving A.R.E. and Engagement with New Audiences” training will give examples of A.R.E.

It is very challenging to develop baseline for my clientele, what should I do?

• The baseline for your clientele group(s) is not expected to be “scientifically sound” and it is understood that it may, at best, be only an estimate arrived at through a good-faith effort if conventional methods do not provide the demographic information you need. You should document and be able to explain how your baseline was developed.The examples shared in this training should help give you ideas.

Recap - Essential Terms

Poll

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Always use ADA and non- discrimination statements in materials and “Justice for All” poster in office and meeting locations.

Civil Rights Compliance Cycle

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4-H Resources and Trainings

Annual 4-H Parity Reporting and 4-H Program Planning

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• By September, previous 4-H program year data collected and submitted to David White in Office of Civil Rights for parity analysis.
• By October, County parity reports are provided to county directors, advisors, community educators, and 4-H Regional Program Coordinators.
• Overall Statewide data is presented by the Office of Civil Rights Analyst on 4-H October Monthly Updates call for discussion and review of program.
• October forward: County staff use previous year parity data results to inform and develop specific actions and procedures for the current year, intended to achieve parity. �

Resources

• 4-H Policy, Chapter 3, https://4h.ucanr.edu/Resources/Policies/Chapter3/
• ANR Administrative Handbook, Section 603, Progarmmatic Compliance https://ucanrpolicy.ellucid.com/documents/view/138/active/

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4-H All Reasonable Efforts Outreach

• USDA requires 4-H clubs, camps and other 4-H units that recruit and enroll youth and adult volunteers, to conduct all reasonable efforts to invite youth and families to participate. All reasonable efforts refers only to efforts made to reach youth and families not already involved in 4-H.
• Reporting All Reasonable Efforts Outreach: Club Leaders, Camp Directors, other Unit Leaders and CES complete the CA 4-H Outreach methods Documentation survey by September 15^th annually. Regional Program Coordinators (or CES supervisor) work with 4-H Community Education Specialists to ensure all 4-H clubs, camps and units complete the survey. The UC ANR Office of Civil Rights reviews information to ensure appropriate documentation.

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Note: Master Gardener Program Coordinators also report All Reasonable Efforts in an annual online survey for their local programs. See Brown Bag webinar.

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Choose your own adventure!

Kit Alviz, Analyst, Program Planning & Evaluation

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Choose Your Own Adventure

Special thanks to UCCE colleagues who provided these examples!

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(1) For the next 20 minutes, choose an adventure of UCCE examples (link in chat)

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(2) After 20 minutes, we’ll have a group discussion (what was helpful, what might you apply, Q&A).

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Tip: Don’t limit yourself to your program area. Consider exploring clientele group types that are similar to yours.

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Questions?

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Group Discussion

Unmute to share verbally or type in the chat:

1. Name, position, clientele, what example(s) you selected
2. What was helpful? Did you learn anything new?
3. Describe one thing that you might apply in your work.
4. What additional questions do you have? (We will follow up later if needed!)

5 minute break

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Mapping tools for assessing parity and civil rights compliance

Priyanka Vyas

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ArcGIS Story Maps

Geoprocessing with Python

ArcGIS Field Maps

Intro to ArcGIS Online

Spatial Analysis with R

DroneCamp

GIS & Drone Services

Workshops

Office Hours

Maggi Kelly

Andy Lyons

Shane Feirer

Sean Hogan

Robert Johnson

Genoa Starrs

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Priyanka Vyas

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sign-up link

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Two tools to assess parity and identify potential clientele

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Business Analyst

ArcGIS for Excel

Today’s focus

Using Statistics to Develop Goals

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Jocelyn Mobley

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How many people DID participate in the program?

Out of the program, what % of participants?

How many people COULD participate?

Of the (county) population, what % of people?

What % do we need to hit to parity?

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Compare

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Civil Rights Compliance Goals

David White

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Civil Rights Compliance Goal Examples

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• Increase participation from individuals in potential clientele groups.

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• Provide feedback to volunteers/staff about beginning and end of year civil rights compliance plans.

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• Review and update baseline data.

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• In collaboration with key community leaders, develop, implement, and assess new All Reasonable Effort methods to improve engagement with one group who was under-represented in my program’s statistics. For example: Latino communities. Form partnership with a local Spanish radio station, identify key educational messages for the community, deliver mass outreach and education, and assess differences in in-person and virtual/remote Latino participation.

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• Start conducting and reporting A.R.E. when I form a new advisory committee with external members.

OTHER CIVIL RIGHTS RESOURCES

UC Office of the President/Systemwide Title IX Office: The Systemwide Title IX Office addresses the university’s obligation to prevent and address sex discrimination, including sexual violence and sexual harassment, in all university programs and activities.

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Academic and Staff Assistance Program (ASAP): This office offers non-emergent confidential, cost free assessment, intervention, consultation and referral services to all employees and their immediate families.

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Center for Advocacy, Resources & Education (CARE): CARE advocates are able to provide confidential help with processing emotions, going over reporting options, resource referral and more if you or someone close to you has experienced sexual harassment or any form of sexual violence.

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OTHER CIVIL RIGHTS RESOURCES (cont.)

Confidential Whistleblower Reports and Complaints – ANR employees can anonymously and confidentially report issues, concerns and questions regarding activities that appear to be unethical, illegal or threatens anyone’s health or the safety of UC employees.

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Abusive Conduct in the Workplace policy prohibits abusive conduct and retaliation. ANR Employee and Labor Relations Office intake complaints of abusive conduct through the following email: anr_abusive_conduct@ucdavis.edu.

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Academics: Project Board Tips

• To streamline reporting: Consider condensing multiple clientele groups identified in your needs assessment into a single Project Board clientele group
• Use available US Census data provided by UC ANR
• All Project Board clientele groups are assessed for compliance. Omission of reporting on a clientele group may result in a non-compliance finding.
• Project Board training is Sep. 26th 1-3PM
• Other Project Board user manuals still being updated

See Project Board civil rights compliance (updated August 2025) : https://ucanr.edu/sites/ProjectBoardHelp/Affirmative_Action__Civil_Rights_Compliance_Training/#crcfaq

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Q&A & Feedback

Contact Information

Tina Jordan� Interim Civil Rights Compliance Officer� Academic HR Manager� Phone: (530) 750-1280� tljordan@ucanr.edu�

David White�Civil Rights Compliance Analyst� Phone: (530) 786-0206� dewhite@ucanr.edu�

For Project Board Assistance:

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Kit Alviz� Program Policy Analyst� Phone: (510) 987-0027� kit.alviz@ucop.edu�