Appendix - W-2 Agency Civil Rights Obligation

Title VI of the Civil Rights Acts of 1964 and 1991, Section 504 of the Rehabilitation Act of 1973, Title IX of the Educational Amendments of 1972, the Age Discrimination Act of 1975 and Title II of the Americans with Disabilities Act of 1990 all have similar requirements for recipients and subrecipients of federal funding.  Basically, these laws require taking affirmative actions to ensure equal opportunity in service delivery and overcome the discrimination against people of race, color, national origin, religion, age, gender, or disability.  These characteristics are considered protected from discrimination and are considered to be members of protected groups under the above laws.

The United States (U.S.) Department of Justice (DOJ) is responsible for coordinating the development and publication of uniform requirements, procedures, and regulations which apply to recipients and subrecipients of federal funding.  The United States (US) Department of Health and Human Services (DHHS) and other federal departments which provide funding for services to clients have responsibility for issuing regulations and requirements to implement civil rights laws.  The Regional Offices of Civil Rights, operated by the federal departments, provide technical assistance to state agencies such as the Wisconsin Department of Children and Families (DCF) and other recipients of federal funding to ensure uniform implementation of the civil rights regulations.  These regional offices develop agreements of mutual responsibilities and formally investigate any complaints received from clients of federally funded services.

The Wisconsin DCF has primary responsibility for overseeing civil rights compliance (CRC) of all subrecipients of federal funding, including county agencies, for profit and non-profit entities, departments or boards (hereafter referred to as ”W-2 agencies”) and other providers of health and human services.  This oversight includes the provision of technical assistance, the establishment of civil rights assurance requirements and responsibilities for their implementation, requiring assurance of non-discrimination, formally investigating civil rights complaints from clients of federally funded services and monitoring provider agency compliance.  

All W-2 agencies have responsibility to follow the uniform requirements established by DCF which includes, but is not limited to, providing training to agency employees and subcontractors, completing, and maintaining a Civil Rights Compliance (CRC) Plan, and having that plan on file in your agency.  The CRC plan, which includes the requirements for affirmative action and equal opportunity for service delivery and assuring language access to services for all limited English proficient (LEP) groups residing in the service area, must be updated every four years.  

It is critical that each agency staff person review the DCF CRC Requirements Policy, the CRC Plan or the 2006 CRC Webcast Training to ensure a basic understanding of the CRC requirements as well as staff roles and responsibilities related to service delivery and Title VI.  Please note that CRC Plan Requirements allow you to select the training segments based on the size of your agency.  The following is a link to all DCF Civil Rights Compliance requirements, including policies and procedures that W-2 agencies must follow:  http://dcf.wisconsin.gov/civilrights/.  

Questions related to these requirements can be directed to your local W-2 Agency Equal Opportunity Coordinator, Complaint/Grievance Coordinator, or DCF Equal Opportunity Officer, (608) 422-6889 (Voice) or at 711 (TTY Toll Free).

 

 

History: There are no previous versions of this policy.