This page provides information and links that will assist grantees in complying with three mandatory federal processes. These include: civil rights laws and regulations prohibiting discrimination in federally assisted programs or activities; Limited English Proficiency (LEP) guidelines; and, Equal Employment Opportunity Plans (EEOP). These processes are required of recipients of VAWA, VOCA, and SASP funding through the Oregon Department of Justice Crime Victims’ Services Division (CVSD).
As the state administering agency for the Victims of Crime Act (VOCA) funds and the Violence Against Women Act (VAWA) funds, CVSD has implemented three policies that recipients of federal funds must use to respond to discrimination complaints from their employees, clients, customers, program participants or consumers. For questions or help, please contact the CVSD Civil Rights Complaint Coordinator, Shannon Sivell, at firstname.lastname@example.org.
Policy 1: Procedures for Responding to Discrimination Complaints from Employees of the Oregon Department of Justice, Crime Victims’ Services Division’s Subrecipients under U.S. Department of Justice Grant Programs.
Policy 2: Procedures for Responding to Discrimination Complaints from Clients, Customers, Program Participants, or Consumers of the Oregon Department of Justice, Crime Victims’ Services Division and the Oregon Department of Justice, Crime Victims’ Services Division Subrecipients.
Policy 3: Civil Rights Compliance Requirements Specific to State Administrating Agencies: Methods Of Administration.
Notification Regarding Program Availability
CVSD grantees receiving federal funds are required to inform applicants, participants and potentially eligible persons of the policy of nondiscrimination and the procedure for filing a civil rights complaint. CVSD developed a “Civil Rights Fact Sheet” to assist grantees with the information required to be posted at locations open to the public and required to be displayed on all forms of communication available to the public regarding program availability.
CVSD grantees are required to take CVSD-sponsored civil rights training. CVSD Grantees who are unable to attend civil rights training offered by CVSD must view the CVSD Civil Rights & Grants Powerpoint presentation and complete at least one of the online training modules available on the Office for Civil Rights of the U.S. Department of Justice (OCR) website:
- What is the Office for Civil Rights and What Laws Does It Enforce?
- What Obligations Do Recipients of Justice Department Funding Have to Provide Services to Limited English Proficient (LEP) Persons?
- What are the Civil Rights Laws that Affect Funded Faith-Based Organizations?
- What Civil Rights Protections Do American Indians Have in Programs Funded by the Justice Department? What are the Obligations of Funded Indian Tribes?
- What are the Standard Assurances and How Does the Office for Civil Rights Enforce Civil Rights Laws?
OCR online civil rights training can be found at: http://ojp.gov/about/ocr/assistance.htm
Grantees must certify that they have completed civil rights training by signing the Civil Rights Training Certification form and uploading it into E-Grants. The Civil Rights Certification Form must be updated every two years.
Click here for links to the specific nondiscrimination statutes and regulations to which CVSD grantees receiving federal funds are expressly required to comply.
Limited English Proficiency (LEP)
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of national origin. Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency,” requires all recipients of federal financial assistance to provide meaningful access to Limited English Proficient (LEP) persons. Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English can be LEP and may be entitled to language assistance with respect to a particular type of service, benefit, or encounter. CVSD federal grant recipients are required to take reasonable steps to ensure meaningful access to their programs and activities by LEP persons. LEP guidance and requirements for CVSD grantees receiving federal funds can be found at http://ojp.gov/about/ocr/lep.htm.
Equal Employment Opportunity Plan (EEOP)
The EEOP analyzes a grantee's labor market data and employment practices to identify possible barriers to participation of women and minorities in the grantee's workforce.
All grantees of US Department of Justice funding through CVSD must comply with EEOP requirements. The following CVSD grantees may claim a complete exemption from the EEOP requirement
- Grantee has fewer than 50 employees
- Grantee is a non-profit organization
- Grantee is a medical institution
- Grantee is an Indian Tribe
- Grantee is an educational institution, or
- Grantee is receiving an award less than $25,000
To help you decide whether or not you need to file an EEOP, CVSD developed an EEOP Compliance Chart: EEOP Compliance Chart
CVSD Grantees receiving federal fund complete an EEOP Certification, a required Exhibit of a Grant Agreement: Exhibit D EEOP Certification
For grantees that are required to develop an EEOP, specific instructions on how to develop a plan are included in OCR's EEOP Short Form Builder, which may be accessed at http://ojp.gov/about/ocr/eeop_comply.htm. The plan should be submitted to the US Department of Justice, OJP as indicated.
The EEOP Short Form Builder also provides a process to help you determine if your organization must file an EEOP.
The OCR website includes information about when an EEOP is required and how to develop an EEOP: http://ojp.gov/about/ocr/faq_eeop.htm.