A Model for Conducting Internal Compliance Reviews

1. A Model for Conducting Internal Compliance Reviews By Julie N. Middleton, Ph.D. University of Missouri Extension National Extension & Research Administrative Officers’ Conference May 25, 2011 Anchorage, AK

2. Federal law requires periodic reviews of offices to ensure that they are in compliance with Civil Rights laws and regulations.

3. The Missouri Model • Internal Civil Rights Compliance Review consists of three parts on a three-year cycle:

4. Role of the AA/EEO Officer • Provide leadership for reviewing each county every three years at a central location. • Review and sign all Civil Rights files. • Provide necessary training and updates (fragrance free, sexual harassment, accurate reporting, diversifying the council, statewide programming summary, inclusive workplace).

5. Role of Regional Director • Program participation data • Public notification requirements • “Justice for All” poster, brochures and news releases, non-discrimination statement, program complaint poster • Complaint procedures • ADA self-assessment See the Regional Director Internal Compliance Review Form at: http://extension.missouri.edu/staff/EEO/RDICRForm.doc

6. Role of County Faculty and Staff • Ensure familiarity with the office Civil Rights laws and their implications. • Update Affirmative Action plan and report each year. • Focus on methods of conducting “all reasonable efforts” to reach underserved audiences. • Ensure accessibility of all programs. • Provide pertinent information to the Civil Rights file. • Participate in the internal compliance review as requested.

7. Role of the County Program Director • Provide leadership in the county for gathering the Affirmative Action plans and running reports. • Ensure that Civil Rights file is complete and that all personnel have contributed to and reviewed the file. • Attend one-day regional review with Regional Director and AA/EEO Officer. • Sign the Notification of Review Form.

8. Role of the Statewide Program Director

9. On-site Visit by RD Internal Civil Rights Compliance Review On-site Visit By Regional Director County: __________________ Date: __________ Role of the Regional Director in the On-Site Visit

10. County personnel (faculty, staff, & county secretaries) by race & gender • County demographics by race & gender Comments or strategies for continuation and improvement:

11. On-site Visit by AA Director County: __________________ Date: __________ FILES - LAWS, REGULATIONS, RULES, PRONOUNCEMENTS Check when included.

16. Public Notification Requirements

17. Efforts For each county office, the CPD must ensure appropriate Civil Rights efforts. Every three years, the AA/EEO team will conduct an internal review to include:

19. LIST OF COUNTY EXTENSION PERSONNEL (name, ethnicity, gender; add to County Civil Rights File)

20. UNIVERSITY OF MISSOURI EXTENSIONCOUNTY COMMITTEE REPORT List each Extension committee in your county, and add to County Civil Rights File. Year ______

21. OUTSIDE GROUP REPORT List all outside groups that are receiving substantial educational assistance, and add to County Civil Rights File. Year ______

22. UNIVERSITY OF MISSOURI EXTENSION 4-H ACTIVITY FORM (USDA 237 may be substituted.) List all 4-H activities and demographics of the participants. Year ______

25. CERTIFICATION OF REASONS FOR NON-PARTICIPATION (Form CR-2) TO: ______________________________________ (Regional Director) Extension Region: ___________ County: _________ Club Name: ________________ Date Organized: _____ Identify geographic area (town, community, neighborhood). Be as specific as possible.

26. ANNUAL CERTIFICATION OF COMPLIANCE FOR 4-H CLUBS (Form CR-3) Extension Region: _______________________________  4-H  FCE Clubs I have reviewed the “Certification of Reasons for Non-participation for Clubs Where Interracial Mix is Possible but not Achieved” membership forms for 4-H/FCE Clubs and the annual Civil Rights report for this region, and certify the clubs to be in compliance with the Civil Rights requirements as outlined in the Affirmative Action Plan for the University of Missouri Extension.

27. Coding Lists • In compliance with federal regulations, University of Missouri Extension is required to collect data and information from applicants for and recipients of federal assistance. This includes establishing and maintaining a system for collecting and reporting data on minority participation in USDA programs. • Data should be filed under safeguards that will prevent any misuse for discriminatory purpose. Such safeguards include restricting records access to authorized personnel, coding racial identification of office records and using only aggregated data in reports to the public. • Mailing lists, meeting attendance lists and program committee lists should be kept as sources of documentation. These lists should be coded to allow for identification of racial categories. Coding should be done in a uniform manner; therefore, the following codes should be used. • 1 – Black • 2 – Hispanic • 3 – Asian or Pacific Islander • 4 – American Indian or Alaskan Native • 5 – White

28. COUNTY EXTENSION COUNCIL MEMBERSHIP Form is printed from the Council Membership On-Line Database Please add to the printout: __________ County __________ Region________ Year NOTE: County Program Directors should complete this form after elections and return to Regional Director by March 1 each year. Include newly elected and appointed members and those remaining on the Council.

29. ACCESSIBILITY SELF-EVALUATION CHECK LIST This form should be completed for the county office and any location where programming occurs. Section 504 of the Rehabilitation Act of 1973 Date: ________________________ County: _______________________ Region: _______________________ Location: ________________________ [Is this the county office or a program location (circle)?] County Program Director: _________________ Please check either yes, no or not applicable (N/A) to each question. If the answer is no, please explain in the corrective action/comment(s) section following each element. It is important to know exact measures/conditions of inaccessible elements and if there are any plans to correct such elements. Suggestions for corrective action may be found at http://www.usdoj.gov/crt/ada/checktxt.htm. Use additional pages as needed. If assistance is needed, please contact the AA/EEO Office at 573-882-3407.

30. ANNUAL NOTIFICATION OF REVIEW FOR CIVIL RIGHTS FILES County: _____________________________________________ I have reviewed the County Civil Rights File and certify it to be in compliance with the Civil Rights requirements as outlined in the Affirmative Action Plan for the University of Missouri Extension. _________________________________ _________________ (County Program Director) (Date) Completed form in Regional Office and county Affirmative Action files.

31. Sample Regional Internal Review Schedule for Regional Directors

32. Sample Schedule for One-Day Visit by Regional Director and AA/EEO Coordinator

33. Statewide Program Area Internal Review: Schedule of Office Visits

34. Results • Faculty and staff are aware of and apply Civil Rights laws and regulations. • Faculty, staff, Regional Directors and County Program Directors take a leadership role in compliance reviews. • 114 counties are reviewed and approved every 3 years. • Programs are accessible. • Under-represented audiences are reached. • State program offices are in compliance.