Virginia Cooperative Extension's Civil Rights Policies and Guidelines

Situation

Sometimes Extension program delivery is interpreted as being limited to specific interest groups. Potential clientele may perceive Extension programs to have some form of membership requirement as a condition of access. Statements made, or actions taken, by Extension employees may be perceived to indicate, or may inadvertently indicate, that either one or both of the above conditions apply to Extension programs. Examples include, but are not limited to, Extension Master Gardeners, livestock or crop associations, 4-H clubs, and 4-H volunteer organizations.

Principle

Any interested resident of a state where a land-grant University is located has the privilege of access to the Cooperative Extension educational programs conducted by such a University.

Policy

All public employees must offer to each prospective member of their clientele equal opportunity of access to their services, work products, and programs.

Extension Organizational Guidelines

Extension employees shall not discriminate among individuals on the basis of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, or marital or family status.

Every resident of Virginia shall have equal access to any educational program conducted by Extension for the general public, subject to the condition that standards of minimum qualification may be established as a basis for acceptance into any program and payment of fees to defray expenses may be required.

Situation

Equal employment opportunity (EEO) laws prohibit specific types of job discrimination with most private employers, state and local governments, educational institutions, employment agencies, and labor organizations.

Principle

All personnel activities are conducted in a manner that assures equal opportunity for all, are based solely on individual merit and fitness of applicants and employees, and are related to specific jobs and without regard to race, color, religion, sex, age, national origin, mental and physical disability, political affiliation, or other non-merit factors.

Policy

Virginia Cooperative Extension programs and employment are open to all, regardless of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, or marital or family status. Virginia Cooperative Extension is an equal opportunity/affirmative action employer. 

Extension Organizational Guidelines

VCE employees should take every opportunity to notify the public that the organization is an equal opportunity/affirmative action employer.

Situation

Public Notification is the process by which the public is advised of VCE programs, the requirements for non-discrimination, and the availability of reasonable accommodations for those needing them.

Principle

A series of communication methods are used to advise individuals and "grass roots" organizations about program availability on a nondiscriminatory basis and notifies them of the procedures for filing a complaint.

Policy

Communication methods must include:

  • Display of the And Justice For All poster at all county/city, district, and state Extension offices
  • Use of the VCE non-discrimination statement in letters, newsletters, and publications
  • Use of the VCE ADA notice about accommodations on forms, applications, program announcements, and brochures
  • Communication about Extension programs at the local level to ensure that all persons, especially those who previously may not have participated fully, know about the availability and effective use of Extension program services and are encouraged to participate
  • Informing organizations and groups with which VCE cooperates of our non-discrimination provisions
  • Use of non-sexist language and non-discriminatory language, photos, and graphics to convey the message of equal opportunity in all programming
  • Provision of materials in alternative means of communication (Braille, large print, audiotape, interpretation, etc.) upon request

Extension Organizational Guidelines

Through the use of newspaper, letters, radio and television messages, posters, etc., the public is notified in a manner that informs all eligible people of Extension programs, their equal access to programs, and their protection against discrimination in the conduct of such programs.

Situation

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. The intent of the Civil Rights Act and the means for achieving that intent 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 underserved audiences and to overcome barriers and concerns that might interfere with their participation. 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.

Principle 

"All Reasonable Efforts" are a combination of actions designed to communicate to all persons that VCE-sponsored club membership and program participation are open and that all are welcome and encouraged to become members or to participate in educational programs.

Policy

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

  1. Use of all available mass media – including radio, newspaper, and television – to inform potential recipients of the program and of the opportunity to participate
  2.  Personal letters and circulars 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 must 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.

In addition, there is an expectation for affirmative action to achieve balanced participation and civil rights compliance in the form of "All Reasonable Efforts" to increase the level of minority participation in and integration of 4-H clubs, and other VCE-sponsored organizations.

The legal guidelines of eliminating discrimination in a state Cooperative Extension program require that, for each 4-H Club whose membership consists of one race and services a community or area of interracial clientele, steps must be taken to assure that membership of such clubs is interracial in composition.

Extension assistance is to be discontinued to those clubs which remain all one race, unless it is established that "all reasonable effort" has been made to recruit individuals of racial groups not represented. In any such case, a record of effort made is required to be retained for audit purposes.

Extension Organizational Guidelines

"All Reasonable Efforts" should be documented and maintained in the unit’s central Civil Rights files.

Situation

VCE works with numerous organizations across the Commonwealth. Because VCE programs are non-discriminatory, the organizations with which VCE collaborates, and provides assistance to, cannot be discriminatory in its policies or membership.

Principle

Virginia Cooperative Extension cannot provide significant assistance to, or collaborate with, any organization that discriminates. This guideline is also in alignment with VT Policy 1025, which states:

"Virginia Tech does not tolerate discrimination or harassment on the basis of age, color, disability, gender, national origin, political affiliation, race, religion, sexual orientation, or veteran status. Such behavior is inconsistent with the University’s commitments to excellence and to a community in which mutual respect is a core value as articulated in the Virginia Tech Principles of Community. The prohibition against discrimination and harassment applies to all levels and areas of University operations and programs, to students, administrators, faculty, staff, volunteers, vendors, and contractors."

Policy

Virginia Cooperative Extension cannot provide significant assistance to, or collaborate with, any organization that discriminates. VCE has an obligation to inform organizations about this policy of non-discrimination. Unit extension staff must have documentation on file about groups or organizations in a collaborative relationship with VCE, or to which significant service is provided, certifying that discriminatory practices are not followed.

Due to the facilitative and partnership nature of Extension programs, the following is offered as a template to be utilized when working with other agencies, organizations, etc. in the conduct of extension efforts.

Template

__________(Agency)__________ does not prohibit access to services or programs on the basis of age, color, disability, gender, national origin, political affiliation, race, religion, sexual orientation, or veteran status.

___Signature of Agency Representative___

Extension Organizational Guidelines

The preceding assurance should be obtained from the respective partner or organization, and placed in the appropriate unit Civil Rights file.  Other evidence of a partner’s commitment to Civil Rights, such as their own respective policies or statements, can also be utilized in place of the above.

Situation

VCE sponsors organizations and clubs to further its work. Examples include 4-H clubs, Extension Master Gardener Associations, Master Naturalist clubs, and Extension Homemaker clubs. As official components of VCE, these clubs and organizations are expected to comply with pertinent civil rights laws and policies.

Principle 

Any interested resident of Virginia has the privilege of access to VCE-sponsored organizations and clubs. To assure that equal access is provided, VCE-sponsored organizations and clubs are expected to annually provide evidence that this is the case.

Policy

All VCE sponsored organizations must annually provide evidence that their organization or club has balanced membership and if not, that they provide evidence of the reasonable efforts that were taken in order to be in compliance. Organizations should use VCE Publication 490-156 each October to document their compliance status. Extension faculty with responsibility for those organizations are responsible to see that each organization is in compliance and that the compliance form is on file in the unit civil rights file.

Extension Organizational Guidelines

The Civil Rights Compliance form must be obtained from each VCE-sponsored organization every year in October and placed in the appropriate unit civil rights file. For VCE-sponsored organizations associated with a program area in a unit for which there is no respective agent, the responsibility to insure compliance with this policy becomes that of the Unit Coordinator or agent appointed by the District Director.

Situation

Virginia Cooperative Extension is a recipient of USDA federal funding and therefore is obligated to take reasonable steps to ensure that those with Limited English Proficiency [LEP] have meaningful access to the programs, services and information provided by Extension. The U.S. Census estimates that 13.2 percent of Virginia residents 5 years and over speak a language other than English at home.

Principle 

VCE strives to comply with applicable federal, state, and local rules and regulations pertaining to the openness of our programs and employment opportunities to all.  Title VI of the Civil Rights Acts of 1964 precludes discrimination on the basis of national origin. Due to the diversity of the population of the Commonwealth, and in the interest of serving those whose native language is not English, VCE will make reasonable efforts to provide alternative methods of educational delivery.  

Extension Organizational Guidelines

Reasonable efforts will be made in identifying LEP persons who require language assistance.  Reasonable alternative methods of educational delivery will be explored, and provided so as not to cause an undue burden on the agency.  The following four-factor analysis will be used to effect the preceding:

  • The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or grantee/recipient
  • The frequency with which LEP individuals come into contact with the program
  • The nature and importance of the program, activity, or service provided by the program to people’s lives
  • The resources available to the grantee/recipient and costs

Any reasonable efforts made in the above regard should be documented and maintained in the unit civil rights files.

Situation

The intent of the Americans with Disabilities Act of 1990 (ADA) is to limit actions or decisions that would adversely impact access to any programs, services, or benefits. Federal law and Virginia Tech’s Anti-Discrimination and Harassment Prevention Policy 1025 prohibit discrimination or harassment of employees, clients, or applicants on the basis of a disability. In addition, retaliation against a person for asserting their rights under these laws and policies is not permitted.

Principle 

Virginia Cooperative Extension complies with the Virginia Tech ADA policy. The purpose of this policy is to provide guidelines to the university community to assure compliance with the Virginia Tech Affirmative Action Plan, the Americans with Disabilities Act of 1990 (ADA), the Rehabilitation Act of 1973 (Revised), the Americans with Disabilities Amendments Act (ADAAA), and Policy Memorandum 178, Accommodation of Disabilities. Additionally, this policy supports the intention of the Principles of Community and is a tool to increase access and inclusion. In Policy 4075, the university community refers to employees, students, Extension clients, and applicants for employment and admission.

Policy

Virginia Tech and Virginia Cooperative Extension are committed to providing reasonable accommodations to members of the university community to enable them to participate as fully as possible in all aspects of the university’s work, learning, programs, and other activities. View the University Accommodations of Individuals with Disabilities (PDF) policy for more information.

Extension Organizational Guidelines

VCE employees should make all reasonable efforts to include all people regardless of disability in all programs, events and employment. Reasonable accommodations will be made whenever feasible. An approved ADA Statement must be used in all methods of promotion of VCE events and programs, including written, verbal, and electronic means for workshops, events, seminars, classes, and organizational meetings

Situation

Individuals may have questions, concerns or complaints about VCE's policies or practices related to Equal Employment Opportunities/Affirmative Action or about program discrimination or accessibility.

Principle 

VCE is committed to compliance with applicable federal, state, and local rules and regulations pertaining to the openness of our programs and employment opportunities to all.  This is consistent with Virginia Tech’s prohibition of discrimination against employees, students, or applicants on the basis of age, color, disability, gender, genetic information, national origin, political affiliation, race, religion, sexual orientation, or veteran status. It is important that we promptly address any concerns about discrimination or harassment, including sexual harassment. Discrimination or harassment is addressed by Virginia Tech's Anti-Discrimination and Harassment Prevention Policy, Policy 1025

Complaints related to civil rights compliance in Extension programs may be filed by any individual, group of program recipients, or potential program recipients. In addition, the public must be told of their right to file a discrimination complaint.

Policy

The public is told of the right to file a complaint through the use of two posters:  1) the USDA "And Justice for All" poster; and 2) the Virginia Tech Sexual and Discrimination Harassment poster. These posters must be visibly displayed in Extension meeting rooms and the main office. The USDA poster advises participants that they can file complaints with the Office of Civil Rights at USDA. This office will investigate and resolve complaints of discrimination in programs operated or assisted by USDA, including Cooperative Extension programs. The VT poster directs clients and employees to a number of resources on the campus.

Another means in which the public is told of this right to lodge a discrimination complaint is by providing clients the VCE Discrimination Complaint Notification Template. The complaint notification template is for use by VCE employees when there is an allegation of a civil rights violation by program participants. This complaint notification should be provided to all Extension program participants on request or when a complaint is made known. The complaint notification offers the following contacts for persons that feel they have been denied access to services or programs on the basis of age, color, disability, gender, genetic information, national origin, political affiliation, race, religion, sexual orientation, or veteran status:

  • The individual providing the program, if they feel comfortable doing so
  • The Extension District Director or other supervisor if not in an Extension district
  • The CALS Director of Civil Rights Compliance
  • The Virginia Tech Human Resources Office for Equity and Access
  • United States Department of Agriculture at:
    USDA
    Director, Office of Civil Rights
    Room 326-W, Whitten Building
    14th and Independence Avenue, SW
    Washington, DC 20250-9410
    (or call USDA at (202) 720-5964)

For specific information about what to include in in a complaint letter, visit: http://www.ascr.usda.gov/complaint_filing_program.html

Extension Organizational Guidelines

VCE encourages, but does not require, clients to try to resolve complaints with the Extension employee providing the program or service at the local level. However, if that is not possible, or if the client’s complaint is not resolved to their satisfaction, then clients should be provided with the VCE Discrimination Complaint Notification Template. Once an allegation has been made that contains any element of discrimination or harassment, the appropriate individuals in VCE and at VT will investigate the complaint.