CIVIL RIGHTS DIRECTORATE Compliance and Procedures Division Gwendolyn

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CIVIL RIGHTS DIRECTORATE Compliance and Procedures Division Gwendolyn King DHS Civil Rights Disbursement Review

CIVIL RIGHTS DIRECTORATE Compliance and Procedures Division Gwendolyn King DHS Civil Rights Disbursement Review Compliance Form United States Coast Guard 2703 Martin Luther King Jr. Ave. SE Washington, DC 20593

TITLE VI AND COMPLIANCE AGENDA • Federal Financial Assistance (FAA) • Assurance Agreements •

TITLE VI AND COMPLIANCE AGENDA • Federal Financial Assistance (FAA) • Assurance Agreements • Compliance Reporting • Compliance Assessment CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 2

TITLE VI COMPLIANCE Federal Financial Assistance (FAA) • Grants and loans • Grants/donation of

TITLE VI COMPLIANCE Federal Financial Assistance (FAA) • Grants and loans • Grants/donation of Federal Property • Detail of Federal Personnel • Sale, Lease, or Permission to Use Federal Property • Any Federal Contract for the Provision of Assistance CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 3

TITLE VI COMPLIANCE Assurance Agreements • Acknowledgement by Grantees to comply with applicable Civil

TITLE VI COMPLIANCE Assurance Agreements • Acknowledgement by Grantees to comply with applicable Civil Rights laws prior to or as a condition of disbursement of funds • Contractual Obligations • Applies to Direct Recipients and Sub-recipients • Includes Language Assistance for Limited English speaking public* SUB-RECIPIENT – Entities to whom Federal Financial Assistance is extended through another recipient, and does not received financial assistance directly from DHS. CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 4

TITLE VI COMPLIANCE Compliance Reporting • Complete Civil Rights Disbursement Review Compliance Form and

TITLE VI COMPLIANCE Compliance Reporting • Complete Civil Rights Disbursement Review Compliance Form and return it to the Department of Homeland Security (DHS) • Every two years • Within thirty (30) days of receipt of the Award or, for State Administering Agencies, thirty (30) days from receipt of form from DHS • Submission of form, including supporting materials, is required to meet compliance requirements CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 5

TITLE VI COMPLIANCE Compliance Reporting (Continued) State Administering Agencies • Form becomes part of

TITLE VI COMPLIANCE Compliance Reporting (Continued) State Administering Agencies • Form becomes part of the Grant application process. • Submit form plus required data with 30 days of receipt to DHS • Provide required data every 2 years Non-Profits • Form becomes part of the Grant application process. • Submit form plus required data to DHS with 30 days of receipt of Notice of Award. Sub-Recipients • Not required to complete and submit form; however, they have the same compliance obligations as their primary recipients. CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 6

TITLE VI COMPLIANCE Compliance Reporting (Continued) What Data is required? • Brief description of

TITLE VI COMPLIANCE Compliance Reporting (Continued) What Data is required? • Brief description of any complaints or lawsuits alleging discrimination during last 5 years. • Brief description of any civil rights compliance reviews, agency conducting reviews, and findings during the 2 -year period before the DHS award. • List of other federal agencies from whom you receive Federal Financial Assistance and whether agencies have found noncompliance in Civil Rights requirements. • Copy of complaint process CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 7

TITLE VI COMPLIANCE Compliance Reporting (Continued) What Data is required? • Affirm that Staff

TITLE VI COMPLIANCE Compliance Reporting (Continued) What Data is required? • Affirm that Staff has been designated to coordinate and carry out compliance requirement for Civil Rights laws and provide a list of staff and the Civil Rights Laws they coordinate and enforce. • Provide copies of policies pertaining to nondiscrimination, Individuals with Disabilities, and Limited English Proficiency (LEP) • Copy of plan to ensure Sub-Recipient compliance with Civil Rights Laws. CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 8

TITLE VI COMPLIANCE Compliance Reporting (Continued) Compliance Resources • Information on obligations regarding nondiscrimination

TITLE VI COMPLIANCE Compliance Reporting (Continued) Compliance Resources • Information on obligations regarding nondiscrimination on the basis of race, color, and national origin: http: //www. dhs. gov/title-vi-overview-recipients-dhs-financialassistance Information on obligations regarding persons with Limited English Proficiency (LEP): http: //dhs. gov/guidance-publishedhelp-department-supported-organizations-provide-meaningful -access-people-limited Information on obligation regarding Individuals with Disabilities: http: //www. dhs. gov/disability-access-department -homeland-security CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 9

TITLE VI COMPLIANCE Compliance Assessment Implementation • When is Implementation? • What will the

TITLE VI COMPLIANCE Compliance Assessment Implementation • When is Implementation? • What will the Assessment consist of? • How often will they be conducted? • What is the current status? CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 10

TITLE VI COMPLIANCE ? CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance

TITLE VI COMPLIANCE ? CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 11

TITLE VI COMPLIANCE How to contact me: Gwendolyn A. King Equal Employment Manager Civil

TITLE VI COMPLIANCE How to contact me: Gwendolyn A. King Equal Employment Manager Civil Rights Directorate United States Coast Guard 2703 Martin Luther King Jr. Ave. SE Washington, DC 20593 O: (202) 372 -4596; F: (202) 372 -8303 gwendolyn. a. king@uscg. mil CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 12

TITLE VI COMPLIANCE Backups CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance

TITLE VI COMPLIANCE Backups CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 13

TITLE VI COMPLIANCE Civil Rights Laws • Title VI of the Civil Rights Act

TITLE VI COMPLIANCE Civil Rights Laws • Title VI of the Civil Rights Act of 1964 • Section 504 of the Rehabilitation Act of 1963 • Title IX of the Education Amendments Act of 1972 • Age Discrimination Action of 1975 NOTE: Must be referenced in nondiscrimination policy. CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 14

TITLE VI COMPLIANCE Case Law No person includes undocumented immigrants. The Supreme Court upheld

TITLE VI COMPLIANCE Case Law No person includes undocumented immigrants. The Supreme Court upheld in 1982, in Phyler vs Doe that undocumented immigrants are considered persons under the equal protection and due process clauses of the 5 th and 14 th Amendment of the Constitution. CIVIL RIGHTS DIRECTORATE Unclassified | Civil Rights Disbursement Review Compliance Form | CG-00 H-11 | Presenter: Gwendolyn King Compliance and Procedures Division 15