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The NC State Extension Civil Rights Plan provides guidance to Cooperative Extension employees on our policies and procedures that have been enacted to ensure we maintain compliance with federal civil rights laws and regulations.

NC State Extension Civil Rights Plan 

INTRODUCTION

NC State Extension transforms science into everyday solutions for North Carolinians through programs and partnerships focused on agriculture and food, health and nutrition, 4-H youth development and community and economic development. Extension programs are planned and conducted in response to the clientele needs and priorities that are aligned with Extension resources and staff competencies. NC State Extension is dedicated to providing high-quality and effective educational programs that comply with all civil rights, equal employment and affirmative action requirements. This commitment extends to providing open and inclusive access to every North Carolinian seeking to participate in our programs and activities and all faculty and staff employment decisions.

NC State Extension is committed to the intent of Titles VI and VII of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, the American’s with Disabilities Act of 1990, and the Age Discrimination Act of 1975. NC State Extension supports equal opportunity in employment, programs and activities; and does not discriminate on the basis race, color, religion (including belief and non-belief), sex (including but not limited to pregnancy, childbirth, or related medical condition, parenting, and sexual harassment), sexual orientation, actual or perceived gender identity, age, national origin, disability, veteran status, genetic information, retaliation based upon a person’s engagement in a protected activity, or any other legally protected status. As such, no person will be excluded from participating in, be denied the benefits of, or be discriminated against in employment or any program or activity conducted by Extension. It is also our position that education and financial assistance will not be provided to any organization or group that excludes individuals because of their membership in a protected class. The Director of NC State Extension will communicate this position to employees, program participants, potential participants, and populations directly affected by programs or activities.

This civil rights plan sets out civil rights administrative policies and procedures and serves as an operational guide to provide information on federal civil rights laws and university policies. Most importantly, this plan will help faculty and staff understand their roles and responsibilities in accomplishing civil rights obligations and goals. All faculty and staff are expected to be knowledgeable and skilled in implementing equal opportunity requirements in Extension programs.

STATEMENT ON NONDISCRIMINATION

NC State University provides equal opportunity and affirmative action efforts, and prohibits discrimination and harassment based upon the following protected status: race; color; religion (including belief and non-belief); sex (including but not limited to pregnancy, childbirth, or related medical condition, parenting, and sexual harassment); sexual orientation; actual or perceived gender identity; age; national origin; disability; veteran status; genetic information; or retaliation based upon a person’s engagement in a protected activity. NC State University will promptly and equitably address allegations of discrimination and harassment in education programs or activities and employment.

LEGAL & POLICY FOUNDATION

Federal Legislation

The legal foundation of our civil rights obligations is grounded in five key pieces of federal legislation and their implementing regulations and directives. NC State Extension’s obligations are triggered through the receipt of federal financial assistance. A recipient of federal financial assistance is any entity that has received federal money in the form of contracts, grants, loans, or other financial assistance. As a condition federal financial assistance, NC State Extension provides an assurance to federal funders that no person shall be discriminated against on the basis of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity or in employment.

TITLE VI OF THE CIVIL RIGHTS ACT OF 1964: No person in the United States shall, on the basis of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. Furthermore, individuals cannot be retaliated against because they made charges, testified or participated in any complaint.

TITLE IX OF THE EDUCATION AMENDMENTS OF 1972: No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving federal financial assistance.

SECTION 504 OF THE REHABILITATION ACT OF 1974: Section 504 forbids organizations and employers from excluding or denying individuals with disabilities an equal opportunity to receive program benefits and services. It defines the rights of individuals with disabilities to participate in and have access to program benefits and services.

TITLE II OF THE AMERICANS WITH DISABILITIES ACT OF 1990 (ADA): State and local governments (to include state universities) are required to give people with disabilities an equal opportunity to benefit from all their programs, services, and activities. State/local governments can’t deny people with disabilities the chance to participate or make them participate in different programs than those available to others.

AGE DISCRIMINATION ACT OF 1975: No person in the United States shall, on the basis of age, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving federal financial assistance.

University Policies & Regulations

NC State University is an equal opportunity and affirmative action employer and provider. All applicants, employees, students and other individuals who participate in university or university-sponsored programs or activities and/or who conduct university business, on- or off-campus, are provided protections under university policies.

POL 04.25.05 – EQUAL OPPORTUNITY AND NON-DISCRIMINATION POLICY: NC State provides equal opportunity and affirmative action efforts, and prohibits discrimination and harassment based upon the following protected status: race; color; religion (including belief and non-belief); sex (including but not limited to pregnancy, childbirth, or related medical condition, parenting, and sexual harassment); sexual orientation; actual or perceived gender identity; age; national origin; disability; veteran status; or genetic information. NC State also prohibits retaliation based upon a person’s engagement in a protected activity.

REG 04.25.02 – DISCRIMINATION, HARASSMENT AND RETALIATION COMPLAINT PROCEDURES: This regulation serves as a companion to NCSU POL 04.25.05 (Equal Opportunity, Non- Discrimination and Affirmative Action Policy) to outline the specific procedures relating to the discrimination, harassment, and retaliation complaint resolution processes at NC State.

POL 04.25.07 – TITLE IX SEXUAL HARASSMENT POLICY: NC State prohibits all forms of sexual harassment and will promptly and equitably address allegations of Title IX sexual harassment in the university’s education programs or activities. NC State also prohibits retaliation under this policy.

REG 04.25.08 – TITLE IX SEXUAL HARASSMENT RESOLUTION PROCEDURE: This regulation serves as a companion to NCSU POL 04.25.07 (Title IX Sexual Harassment Policy) to outline the specific procedures relating to the Title IX Sexual Harassment Complaint Resolution Process at North Carolina State University.

REG 04.25.06 – EQUAL OPPORTUNITY, TITLE IX AND NON-DISCRIMINATION TRAINING FOR EMPLOYEES: This regulation requires all employees to complete an approved training program designed to educate employees about their rights and responsibilities as to NC State’s policies regarding equal opportunity and non-discrimination. Individuals who are “responsible employees” under this regulation must also complete an approved training program that covers the university’s Title IX obligations to prevent and address incidents of sexual assault within the university community.

REG 04.20.05 – SERVICE ANIMALS FOR PERSONS WITH DISABILITIES: This regulation addresses the use of service animals on campus by qualified individuals with disabilities.

REG 05.00.02 – REASONABLE ACCOMMODATIONS IN EMPLOYMENT: NC State provides reasonable accommodations to qualified applicants or employees with known physical or mental disabilities unless it can be demonstrated that the accommodation would create an undue hardship for the institution or lower quality or production standards. This regulation addresses the provision of a reasonable accommodation in employment.

REG 04.25.05 – INFORMATION AND COMMUNICATION TECHNOLOGY ACCESSIBILITY: NC State provides equal access to its educational services, programs and activities in accordance with federal and state laws and, as part of that commitment, to creating an information and communication technology environment that is accessible to all, including individuals with disabilities.

CIVIL RIGHTS RESPONSIBILITIES

The Director of NC State Extension is responsible for organizational compliance with applicable federal civil rights laws and directives, and university policies. The Director makes decisions relative to civil rights implementation and compliance in programs and employment; informs faculty and staff with responsibility for developing, implementing, and evaluating Extension programs of civil rights and affirmative action requirements; and informs all Extension personnel that they have responsibility for promoting balanced program participation of clientele. Effective administration requires delegation of responsibility. Associate and Assistant Extension Directors, Department Heads, State Program Leaders, District Extension Directors likewise affirm their commitment to furthering the educational purpose of Extension in accordance with this plan by virtue of their responsibilities contained herein and through their expressed leadership at state, district, and county levels. The director and members of Extension leadership shall:

• Comply with state and federal legislation and university policies on non-discrimination and equal opportunity.
• Promote a working and learning environment that is supportive of nondiscrimination, equity, and diversity principles and free from unlawful discrimination and harassment.
• Ensure that organizational practices respect the social and cultural diversity contained within the organization; including faculty, staff, volunteers, advisory leadership councils, and the communities we serve.
• Hold employees accountable for adhering to the requirements of civil rights laws and directives.
• Provide unfettered access to complaint resolution avenues, free from retaliation, for all employees and program participants.

The Asst. Extension Director, HR and Operational Strategy oversees compliance with civil rights in employment related activities. The assistant director shall:

• Compile data and reports to assist in affirmative action and equal opportunity compliance.
• Ensure that search committees understand and follow university recruitment, hiring, and promotional policies and procedure.
• Provide training and resources to ensure that employees and applicants understand equal opportunity guidelines.
• Actively identify and develop strategies to remedy barriers to participation in hiring and progression in employment.
• Provide unfettered access to complaint resolution avenues, free from retaliation, for all employees.

The Extension Civil Rights Coordinator oversees compliance with civil rights in program related activities. The coordinator shall:

• Consult with and provide guidance to leadership, administrators, managers and supervisors about nondiscrimination policies, procedures, best practices, and strategies to increase diversity, inclusion, and parity in programs.
• Ensure that employees receive training on civil rights laws and directives.
• Raise awareness of available resources, best practices, and programs.
• Ensure maintenance of civil rights compliance documentation and coordinate any civil rights reviews or audits.

Each County Extension Director is designated civil rights leader for that county with the responsibility to oversee implementation of civil rights policies and procedures in the county. County Extension Directors shall:

• Review civil rights policies and procedures at one or more staff meetings each year.
• Conduct annual internal reviews.
• Hold employees accountable for civil rights compliance.
• Analyze annual participation data for achieving program parity and work with employees to actively identify and develop strategies to remedy barriers to program participation and utilize all reasonable efforts to achieve program parity.
• Ensure that civil rights data and reports and collected and maintained.
• Monitor information/materials being developed and disseminated to ensure that all employees are using appropriate nondiscrimination and accommodation statements.

The Vice Provost for Institutional Equity and Diversity promotes the university’s core values of equity and diversity and ensure university compliance with equal opportunity and nondiscrimination laws, regulations, and policies. The vice provost shall:

• Coordinate and oversee university programs assuring compliance with applicable policies, procedures, processes, best practices, and training in compliance with anti-discrimination legislation and regulations.
• Consult with and provide guidance to senior leadership, administrators, managers and supervisors about nondiscrimination policies, procedures, best practices, and strategies to increase diversity, inclusion, and retention.
• Serve as the University’s Title IX Coordinator and ADA Coordinator.
• Ensure thorough and prompt investigation and resolution of discrimination and harassment complaints from employees, students, and program participants.

Extension employees are responsible to conduct business in accordance with policies and procedures, as described in this document. Faculty and staff, as part of their functional responsibilities with NC State Extension, are expected to be knowledgeable and skilled in implementing civil rights requirements in the development, marketing, and delivery of Extension programs. This expectation applies to faculty and staff working on campus, in county offices, at research stations, or remotely and applies to all programs and activities conducted in whole or in part, by NC State Extension or N.C. Cooperative Extension. In furtherance of these commitments, all Extension employees will:

• Expect a working and learning environment free from unlawful discrimination and harassment.
• Promote an environment in the delivery of programs and services that is supportive of nondiscrimination, equity, and diversity principles.
• Comply with all civil rights policies and legislation.
• Respect the social and cultural diversity contained within our organizations, including volunteers, staff, advisory leadership councils, and the communities we serve.
• Actively identify and remedy barriers to participation by all in our programs.
• Seek out program advisory committee representation from underrepresented groups.
• Provide unfettered access to complaint resolution avenues, free from retaliation, for all program participants.

COLLABORATORS AND PARTNERS

As an institution receiving federal financial assistance through the U.S. Department of Agriculture and other federal agencies, Extension does not discriminate in the treatment of individuals based on their race, color, national origin, sex, age, or disability (protected classes).

• NC State will not enter into partnerships, contracts or provide financial assistance to any organization or group that excludes individuals because of their membership in one of the aforementioned protected classes.
• NC State Extension employees will not provide services to, or to use the facilities of organizations that would result in persons being excluded because of their membership in a protected class.
• NC State Extension employees will not participate in any public meeting or activity if it is known that in such meeting individuals have been or will be illegally discriminated against based on the aforementioned protected classes.
• The NC State Extension (or N.C. Cooperative Extension) nondiscrimination statement shall be included on co-branded event and activity announcements hosted in collaboration with partner organizations and on co-branded educational materials.
• The NC State Extension accommodation statement shall be included on co-branded event and activity announcements hosted in collaboration with partner organizations.

NC State Extension employees will provide partner organizations with a copy of the Notice of Nondiscrimination. It is the responsibility of the employee establishing the partnership or collaboration with another organization to assess whether the partnership is in compliance with nondiscrimination obligations. All employees will log distribution of Notices of Nondiscrimination in the Extension Civil Rights System (XCR).

SUBGRANTEES AND CONTRACTORS

NC State Extension employees will obtain a written assurance from subgrantees and contract program providers specifying that they will operate in compliance with nondiscrimination laws, regulations, policies, and guidance. NC State’s Office of Sponsored Programs has incorporated the specific Civil Rights Assurance language below into the USDA FDP Template for USDA subawards.

“The subrecipient hereby agrees that it will comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. §2000d et seq.), Title IX of the Education Amendments of 1972 (20 U.S.C. § 1681 et seq.), Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794), the Age Discrimination Act of 1975 (42 U.S.C. § 6101 et seq.); all provisions required by the implementing regulations; Department of Justice Enforcement Guidelines, 28 CFR Part 50.3 and 42; and all directives and guidelines, to the effect that, no person shall, on the grounds of race, color, national origin, sex, age, or disability, be excluded from participation in, be denied benefits of, or otherwise be subject to discrimination under any program or activity for which the applicant receives Federal financial assistance; and hereby gives assurance that it will immediately take measures necessary to effectuate this agreement.”

Contracts and agreements with organizations where NC State Extension extends financial assistance should incorporate similar language.

SEPARATION OF CHURCH AND STATE

The United States Constitution Bill of Rights First Amendment requires the separation of church and state. Therefore, government is restricted to secular purposes and must remain neutral and not advance nor impede religion. All Extension programs and activities must operate in a manner that is consistent with the First Amendment. Extension faculty and staff may do educational programs for religious groups but may not carryout programs or projects which advance or impede religion; conduct or incorporate into events any religious service or practice (for example prayers); or adopt creeds that include sectarian references or language, (e.g. ideals of Christian life). Extension events may be held in religious/sectarian facilities provided that attendance is open to persons of all beliefs. Volunteers with Extension programs, such as 4-H, Master Gardeners, and EFNEP function under the direct supervision of Extension faculty/staff and sponsorship of the University and are therefore similarly obligated to uphold constitutional principles.

ADVISORY LEADERSHIP SYSTEM

The Extension Advisory Leadership System is a statewide network of county-based volunteers working to support, and advocate for, Extension programming at all levels. Extension Advisory Leadership System volunteers, as well as other community groups are used to provide input on community issues and needs. All County Extension Agents assemble and work with a program advisory committee designed to support the work they do in their respective Extension program area (4-H Youth Development, Family and Consumer Sciences, and/or Agriculture and Natural Resources). In addition to the program committees, an overall county council serves to coordinate efforts for advocacy and support of the total county program and a state advisory council coordinates advocacy and support of the state program. It is important that Extension recruits and engages a representative group from the community, including those that have been historically underrepresented, to serve as members of these committees to ensure equitable program design and delivery of Extension services.

Data on the demographics of each advisory group and the efforts to recruit diverse membership shall be reported annually. Membership composition of each advisory leadership council and committee shall be reviewed annually by the County Extension Director to ensure balanced representation of the local/service population in terms of race, ethnicity, and gender. In addition, the selection process shall be reviewed to ensure that it is designed in a manner that encourages diversity and/or adequate representation of the service population, and that efforts were made to obtain diversity and/or address barriers to participation. Refer to the Advisory Leadership System Operations Manual for information on membership criteria, recruitment, selection, appointment, and procedures for the advisory leadership system. A parity benchmark of 80 percent is used to identify areas of noncompliance. Each race, ethnicity, and gender group’s representation in the eligible group should be reflected within 80 percent of those who benefit from a program or activity.

Parity =  (%Makeup of Group / % Makeup of Community) x 100

Parity ≥ 80 compliant; Parity < 80 not compliant

Each member of an Extension advisory group must complete the Civil Rights Training for Volunteers and Advisory Group Members upon initial appointment and subsequent reappointments. Completion of this training shall be logged by Extension employees within the Extension Civil Rights Reporting System (XCR).

POTENTIAL AUDIENCE

Potential audiences should be determined at the time of program development to ensure information and educational programming are of interest to and appropriate for protected and underrepresented audiences as well as majority audiences. The potential audience for an Extension program is persons or groups in a defined geographic area who might be interested in or benefit from an Extension educational program.

RECOGNIZING POTENTIAL BARRIERS

Designing and Delivering Programs to Reach Diverse Clientele

Offering a blend of programs to match audience needs, and delivering those programs at times and locations that are suitable for potential clientele, are critical ingredients to achieving balanced participation. Increasing participation by the target audience requires that the program is designed and delivered in such a way as to overcome barriers that might interfere with their participation. Such barriers can include language barriers, cultural barriers, economic barriers, and/or access barriers.

Including community members who represent specific target groups on your advisory committees will increase the relevance of programs offered for members of that group. To achieve balanced participation, Extension must deliver a product that is desired by the target audience. To this end, part of the program planning process includes an assessment of the educational needs of potential audiences, and then to deliver programs in accordance with those needs. Where balanced participation is not being achieved, action should be taken to increase the presence of under-represented groups on advisory committees and program planning activities. Each county shall document the annual efforts made to eliminate potential barriers.

Language Barriers

The inability of an otherwise eligible person to fluently speak, read, write or understand English may hinder their knowledge of and/or ability to access programs and services. Recipients of federal financial assistance should take reasonable steps to provide meaningful access to programs and services for people with limited English proficiency to prevent discrimination on the basis of national origin.

Extension programs and activities normally provided in English should be accessible to limited English proficient persons. If the target audience is likely to include a significant population of non-English-speaking participants, the program should include translated written materials and/or interpretation services. Programs delivered only in English may put limited English proficient speakers at risk of not understanding as they may interpret words or phrases differently. Care should be taken to avoid using slang, jargon, acronyms, and metaphors that can be misinterpreted. An assessment of the county population regarding LEP populations and their needs shall be completed by County Extension Centers at least once every 5 years resulting in the development of a local Language Access Plan.

Cultural Barriers

Cultural barriers are those conditions that limit or exclude participation of groups of potential participants because of different cultural identities or accepted values, beliefs, behaviors, and standards of conduct that are accepted and distinguishable from one societal group to another. Some cultural barriers may exclude potential participants from attending their first event; others may dissuade individuals from returning to a second program.

When planning Extension programs and events, one should consider the impact of cultural barriers. Potential barriers can result from: scheduling events that conflict with major religious/ethnic holidays or events; having programs or events in potentially uncomfortable locations such as churches, schools, government offices or other locations where groups were previously rejected or had unpleasant experiences; using program announcements/promotional materials that do not use inclusive language or images; perception or previous experience about the extent of courtesy, tact, and recognition accorded different cultural groups by Extension staff; program activities that include food or activities that are insensitive to religious or cultural dietary or behavioral restrictions, and others.

Economic Barriers

Economic barriers are those conditions of an economic nature that can limit or exclude participation of members of different groups and should be avoided. Examples include programs or activities that require extensive purchases of equipment or supplies; programs that involve fees, meals, specific attire, and travel; and programs that are conducted at certain times of the day or certain days of the week, and locations that require transportation.

Programs intended to target limited-resource audiences may not succeed if participants are required to drive to the event. Locating programs in close proximity (walking distance) may be needed to attract persons with limited means. Similarly, families with small children, single parents, two-earner households, or other underserved audiences may be unable to participate in Extension events at certain times of day or certain days of the week. Programs need to be planned in anticipation of participant needs and delivered to maximize access and minimize barriers to participation.

Access Barriers

Barriers to access are conditions or obstacles that prevent individuals with disabilities from using or accessing knowledge and resources as effectively as individuals without disabilities. Each county shall complete an accessibility self-assessment. Access barriers can be a result of employees not being aware that difficulties getting to or entering a program location can limit a person with a disability from participating. Access barriers include physical or structural obstacles in natural or manmade environments that prevent or block mobility (moving around in the environment) or access. Examples of physical barriers include steps and curbs that block a person with a mobility impairment from entering a building or using a sidewalk, lack of accessible transportation, and tables or desks that do not accommodate a wheelchair. Barriers may also arise from stereotyping those with disabilities, assuming their quality of life is poor or that they are unhealthy because of their impairments. Communication barriers are experienced by people who have disabilities that affect hearing, speaking, reading, writing, and or understanding. Examples of communication barriers include use of small print or no large-print versions of material; no versions for people who use screen readers; videos that do not include captioning; and oral communications without accompanying manual interpretation (such as, American Sign Language). The use of technical language, long sentences, and words with many syllables may be significant barriers to understanding for people with cognitive impairments.

BIAS FREE COMMUNICATION

Bias typically involves a leaning or predisposition on an issue that may inhibit being neutral when communicating with others. When bias exists in attitudes, it is often reflected in the language and the way in which individuals interact with each other. Language can have a significant impact on the quality of our interactions. Many times, we do not intend to exclude or offend others by the words we choose. We may simply lack information about, and sensitivity to, certain words or phrases. Being aware and mindful of our language, both written and oral, can help create a supportive and inclusive climate. The key to effective bias-free communication is treating all people with respect and consideration regardless of personal characteristics such as age, gender, race, color, religion, national origin, or disability.

LANGUAGE ACCESS

Individuals who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English are limited English proficient, or LEP. These individuals may be entitled language assistance with respect to Extension services or benefits. Extension has two main ways to provide language services: oral interpretation either in person or via telephone interpretation service and written translation. The CALS language access plan and County Center language access plans are documents that spell out how to provide services to individuals who are non-English speaking or have limited English proficiency. All employees are required to complete language access training that covers language access requirements and methods of securing language services. The language access log shall be completed in XCR each time a language access request is received. County Extension Centers may request funding to pay for language access services from Extension Administration. Extension Specialists and other campus-based employees should include funding for language services in program budgets and grant requests. Additional information on language access is available on the LEP website.

PROGRAM ACCESSIBILITY FOR PEOPLE WITH DISABILITIES

NC State Extension will make reasonable modifications to its programs, services, and communications upon request for people with disabilities, unless it is demonstrated that making the modifications would fundamentally alter the nature of services, programs or benefits. Programs will be delivered at locations that are physically accessible for people with disabilities. To determine the types of auxiliary aids or services that are necessary, primary consideration will be given to the requests of people with disabilities. Extension will honor the choice of the person requesting the auxiliary aid or service unless it would fundamentally alter the nature of the service, program or benefit or cause an undue administrative or financial burden. If this happens, another equally effective auxiliary aid will be provided. All requests for accommodations shall be reported in the XCR reasonable accommodation log. County Extension Centers may request funding to pay for reasonable accommodations from Extension Administration. Extension Specialists and other campus-based employees should include funding for reasonable accommodations in program budgets and grant requests.

All publicly available electronic resources including, but not limited to, websites, social media sites, e-learning, documents, and videos developed and/or maintained by Extension must be accessible in order to provide equal access and equal opportunity to people with diverse abilities. Examples of electronic accessibility include images on websites should include equivalent alternative text in the markup/code, text transcripts provided with all podcasts to make the audio information accessible to people who are deaf or hard of hearing, use of captioning during virtual meetings, and all videos must include closed captioning.

To communicate our commitment to accommodate special needs, a statement offering reasonable accommodation shall be included on all program and event announcements, including information about whom to contact for assistance and a deadline by when such requests are to be made. The following statement is to be included on all event/program materials and announcements:

In compliance with the Americans with Disabilities Act, {N.C. Cooperative Extension or NC State University} will honor requests for reasonable accommodations made by individuals with disabilities. Please direct accommodation requests to: {EventCoordinatorName, Email, or Phone Number}. Requests can be served more effectively if notice is provided at least 10 days before the event.

PUBLIC NOTIFICATION

Public notification is the core of our civil rights efforts. In addition to identifying and removing potential barriers to program participation during the program planning process, it is necessary that the target audience is aware of program opportunities, their right to participate, and that they feel welcome. Extension must take the necessary steps to inform the public that it does not discriminate, adheres to all civil rights laws, and services are available to everyone. Two primary methods of providing public notification of the right to participate in Extension programs include: prominent display of the USDA “And Justice for All” poster in public areas and all meeting rooms where programs or activities are being conducted and the use of the nondiscrimination statement on print and electronic materials.

A nondiscrimination statement is required on to appear on print and electronic documents and websites that are made available to the public, including participants, students, applicants, and volunteers. The more comprehensive non-discrimination statement is preferred; however, the abbreviated statement may be used when space is limited. In addition, an accommodation statement is required to appear on all marketing and event announcements.

NC State University Nondiscrimination Statement

NC State University {“NC State University” may be replaced with NC State Extension or N.C. Cooperative Extension} promotes equal opportunity and prohibits discrimination and harassment based upon one’s race; color; religion (including belief and non-belief); sex (including but not limited to pregnancy, childbirth, or other related medical condition, parenting, and sexual harassment); sexual orientation; actual or perceived gender identity; age; national origin; disability; veteran status; genetic information; or reprisal or retaliation for prior civil rights activity.

The short version may be used on materials with limited space including postcards trifolds, and documents 2 pages and under.

NC State University is an equal opportunity provider. {“NC State University” may be replaced with NC State Extension or N.C. Cooperative Extension}

BALANCED PARTICIPATION

The goal of civil rights laws and of our policies is to deliver programs to all people who will benefit, regardless of their human characteristics or situation. Civil rights efforts are designed to afford members of our potential audience with the opportunity to participate in Extension programs and receive information and services. As an indicator of our success, our portfolio of programs should result in balanced participation. Balanced participation occurs when the ethnicity, race, and gender of participants across our portfolio of programs are representative of the county population as a whole. Parity is a more widely used term for balanced participation. Parity occurs because Extension uses specific strategies to assess needs, design and deliver relevant programs, remove barriers to program participation, and notify the public about opportunities to participate. An Extension program is considered in parity when the participation of individuals reflects the proportionate representation in the population of potential recipients. A program will be considered to have balanced participation at minimum level of 80% of parity. To ensure equitable distribution of benefits, the composition of beneficiaries of programs and activities should achieve balanced participation or targeted efforts should be implemented to address identified parity concerns. For example, if a program has 10% Hispanic participants and the county has a 20% Hispanic population, your program is at 50% of parity [(10/20) X 100]. Because the level of parity is less than 80%, all reasonable efforts will need to be taken to increase participation by underrepresented groups.

Parity =  (%Makeup of Group / % Makeup of Community) x 100

Parity ≥ 80 compliant; Parity < 80 not compliant

OUTREACH EFFORTS

All reasonable efforts consist of a series of approaches used to solicit participation of underrepresented groups in Extension programs and the Advisory Leadership System. These are documented efforts to target and solicit the participation of individuals from identified underrepresented groups. A sincere effort shall be made to encourage participation by underrepresented groups; it is not enough to simply announce the program is open to all. All reasonable efforts to achieve balanced participation may include:

• Establishing outreach programs at the local level to ensure that all persons, especially those who previously may not have participated fully, know about the availability of Extension program services, and are encouraged to participate.
• Using inclusive and non-discriminatory language, photos and graphics to convey the message of equal opportunity in all programming.
• Using positive examples of program participation by all protected groups in all forms of visual, print, electronic, and audio public information materials.
• Disseminating public notifications to protected groups and underserved populations in English and other languages appropriate to the local population.
• Using available mass media, including radio, newspaper, posters, newsletters, television, websites, and social media to inform potential recipients of program opportunities.

Documentation shall be collected and reported annually to show that “all reasonable efforts” have been made to notify potential participants. Copies of mass media releases, newsletters, etc. are sufficient documentation that the public has been notified. Personal visits may be documented by recording and filing details of the visits including: the name of the contact person, date and location of the visit, the person making the visit, and any summary responses and other related information about the visit. Each County Extension Center should collect examples of all reasonable efforts that may include:

• Flyers, press releases, personal letters, emails, invitation letters and other outreach correspondence and brochures sent to targeted individuals and organizations with notations of where and when the information was sent.
• Notes about all special targeted efforts to reach people from underrepresented groups.
• Notes from meetings and phone conversations that demonstrate your outreach to people from underrepresented groups.

MAILING LISTS POLICY

North Carolina State University, as a constituent institution of the University of North Carolina and an agency of the State of North Carolina, is open and responsive to information requests from the public and the news media. NC State Extension is committed to a policy of openness, honesty, and cooperation with members of the public and the news media.

Mailing lists are maintained for the purposes of emailed and mailed communications. Appropriate management of these lists is important because Extension has a responsibility to those people about whom information has been collected, to protect the information and appropriately steward its use. Management of mailing lists is also necessary to ensure they are used only for purposes appropriate to a publicly funded organization. As a USDA cooperating organization, Extension also has the responsibility to ensure lists are created and updated with the intent of providing equal access to information by the appropriate inclusion of racial/ethnic minorities, members of both sexes and the disabled.

All mailing lists developed by Extension faculty and staff, in the course of their employment responsibilities, are reserved solely for use in furthering the professional and educational goals of Extension and its programs. Lists may not be used for personal purposes or to express personal opinions unrelated to the Extension-related work. Communications that may be interpreted as inappropriate to a public organization or workplace, including expressions of religious belief, political commitment and Extension business are prohibited. Use of Extension lists by Extension faculty and staff to conduct commercial transactions are prohibited.

Members of the public may seek public records from NC State by submitting a written request to the University Records Officer, NC State University, Office of General Counsel, Campus Box 7008, Raleigh, NC 27695- 7008. Additional information can be found in NC State REG 04.00.02 – Public Records Requests.

DATA COLLECTION

As a recipient of federal financial assistance, NC State Extension is required to maintain evidence that programs and services are provided in a nondiscriminatory manner. All Extension programs must collect and securely maintain data on the race, ethnicity and gender (REG) of the program’s participants. In the majority of cases, this data is collected and reported by County Extension Agents in the Extension Reporting System (ERS). However, Extension Specialists and Associates conducting programs not associated with a County Agent are responsible for collecting and maintaining their program data for 3 years. If the program registration is conducted through Extension Eventbrite or the NC State Reporter system demographic questions have been included in the standard registration form to comply with federal requirements. Collection of demographic data is used to evaluate the level of participation by various clientele groups.

The starting point for the race and ethnicity data collection standards is OMB’s current government-wide standard. Collected data must include the race, ethnicity and gender for program participants. Pursuant to federal guidelines for the collection of demographic information self-identification is the preferred means of obtaining information about an individual’s race, ethnicity, and gender. The surveyor should not tell an individual how they should classify themself. This is the most accurate method for collecting demographic information since the clientele are disclosing their ethnicity, race, and gender information.

This self-reporting format shall be accomplished in a manner that protects the privacy of individuals by utilizing demographic questions on registration forms, self-report paper and pencil surveys, or electronic surveys. Participants should be informed that providing demographic data is voluntary and requested solely for the purpose of determining compliance with federal civil rights laws, and their response will not affect eligibility to participate in Extension programs.

To provide flexibility and ensure data quality, separate questions for ethnicity and race should be used. Specifically, ethnicity is asked first and then race. The categories for ethnicity are: Hispanic or Latino and Not Hispanic or Latino. The categories for race are: American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, White, and Other. Respondents who wish to identify their multi-racial heritage may choose more than one race. The categories for gender are male and female. Program participants may also be provided with “prefer not to respond” options for ethnicity, race, and gender.

Civil rights compliance data is also collected withing the Extension Civil Rights Reporting System (XCR). The XCR system is a repository to collect and maintain records of civil rights activities both on campus and in the counties. The XCR system contains a means to submit a variety of information including:

• Requests made by clientele for language access services
• Requests made for clientele for reasonable accommodations
• Records of Notices of Nondiscrimination distributed to partner organizations
• Records of employee and volunteer training pertaining to civil rights topics
• Local language access plans (submitted once every 5 years)
• County Center facility accessibility checklists (submitted once every 5 years)
• Annual county civil rights internal review checklists
• Annual district civil rights internal review forms

TRAINING

It is expected that employees routinely participate in civil rights and language access training. New employees are required to complete an Extension new employee civil rights training module within the first three months of employment as part of the new hire onboarding process. Documentation of the completion of civil rights onboarding training is maintained by Extension Organizational Development (EOD). Refresher training will be provided to all county employees during each year a district review is conducted. In addition, all employees are required to complete Discrimination and Harassment Prevention and Response (DHPR), a training designed to educate employees about their rights and responsibilities as to NC State’s policies regarding equal opportunity and non-discrimination. The training covers federal laws, policies and processes about filing a complaint. Employees are required to complete the training within the first six months of employment and then once every three years thereafter. The training is offered to all new employees during new employee orientation and can be completed virtually.

Routine online civil rights refreshers and updates will be made available to employees. Other opportunities for civil rights training will be provided annually as part of district meetings, county staff meetings, in-service training events, annual conference, newsletters, memos, etc. Volunteers, advisory council members, and club/group leaders shall also be provided civil rights training so they understand civil rights laws, Extension’s responsibilities in programming, what their roles are and what they can do to help Extension in their civil rights goals.

Employees designated as Designated Title IX Officials and Responsible Employees are required to complete a training program that includes information about the obligations of responsible employees under Title IX with respect to sexual harassment (including sexual assault and sexual violence) within six months of their appointment into a Designated Title IX Official and/or Responsible Employees position.

All Extension employees delivering training to staff or volunteers must document the training in the XCR system. Documentation of training shall include submission of agendas, slide decks, and participant lists.

COMPLAINT RESOLUTION

Extension is committed to compliance with applicable federal, state, and local laws pertaining to equal access to programs and employment opportunities. Any individual, group of program participants, or potential program participants who believe they have been discriminated against on the basis of race, color, national origin, sex, age, or disability may file a civil rights complaint.

The public is informed of this right by the prominent display of the USDA “And Justice for All” poster. This poster must be displayed in all Extension offices and campus facilities where program services are provided. Another means in which the public is informed of their right to lodge a discrimination complaint is the NC State Extension Discrimination Complaint Brochure provided to program participants upon request or when an Extension employee or volunteer is made aware of a potential complaint.

No one may, in any way, try to interfere with the filing of a formal complaint. However, Extension employees are encouraged to inquire about the nature of the complaint, and to offer the individual any assistance or remedies that are within the scope of our policies. In all cases, Extension Administration is to be informed immediately when such events occur. Extension encourages, but does not require, clients to try to resolve complaints with the Extension employee providing the program or service at the local level. When a client voices a concern about possible discrimination in a program, the employee receiving the complaint should listen carefully. The client should be made aware that they have the right to file a complaint.

Individuals should be made aware of the available avenues for filing a complaint. Individuals may take their concern to the County Extension Director as a step in the informal complaint process where the County Extension Director shall act promptly to mediate, conciliate, or otherwise achieve informal resolution. The client should also be made aware that they have the right to file a formal complaint with the NC State Extension Director, NC State University, or send notification of the complaint directly to the USDA.

If the client decides not to file a formal complaint, the employee receiving the concern and the County Extension Director should document by letter to the client, a summary of the discussion, and the corrective action to be taken or already taken concerning the issue. In the letter, the client should be informed of their right to file a formal complaint by providing them with a copy of the Discrimination Complaint Brochure. A copy of the letter should be forwarded to the NC State Extension Director, the District Extension Director, and the NC State Extension Civil Rights Coordinator.

Any individual who feel they may have experienced discrimination, harassment, and/or retaliation based on a protected status has a right to file a report through the University’s Discrimination, Harassmnet, Title IX, and Retaliation Report Form. Individuals may also choose a consultation that will include discussing university resources, supportive measures, and the complaint procedures available. Individuals who are interested in a consultation can contact Equal Opportunity and Equity (EOE) via email at equalopportunity@ncsu.edu or via phone at 919.513.0574. The File a Report page includes additional information regarding reporting options. NC State will promptly, thoroughly, and impartially respond to all complaints of discrimination, harassment and retaliation. Any individual with a complaint of discrimination, harassment or retaliation should follow NC State’s Discrimination, Harassment and Retaliation Complaint Procedure (Reg. 04.25.02). Substantiated instances of discrimination, harassment, and retaliation, as defined above, are violations of university policy and will not be tolerated by NC State. Appropriate corrective measures will be instituted for violations. Such corrective measures will be designed to stop the discrimination, harassment and/or retaliation and to prevent future violations. Corrective measures may involve disciplinary action or discharge.

USDA prohibits discrimination against its customers. If an individual believes they experienced discrimination when obtaining services from a program that receives financial assistance from USDA, they may file a complaint with USDA. OASCR, through the Center for Civil Rights Enforcement, will investigate and resolve complaints of discrimination in programs assisted by USDA. To file a program discrimination complaint with the USDA, a complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form, which can be obtained by sending an email to CR-Info@USDA.gov, from any USDA office, by calling 866.632.9992, or online at https://www.usda.gov/sites/default/files/documents/ad-3027.pdf

NC State employees may file formal complaints for violations of the NC State Equal Opportunity and Non-Discrimination Policy (Pol. 01.25.05) for acts of discrimination, harassment, or retaliation. Employees are encouraged, and should feel free, to seek assistance, information, and guidance within NC State from any of these resources: Immediate Supervisor, Extension Administration, Office for Institutional Equity & Diversity, or Human Resources. To file a workplace-related complaint, complete the Discrimination, Harassment, and Retaliation Complaint form which provides preliminary information to the Office for Institutional Equity and Diversity to assist in resolving violations of NC State University’s Equal Opportunity and Nondiscrimination Policy. The form can be accessed at the NC State Equal Opportunity and Equity section’s website: https://diversity.ncsu.edu/report-a-concern/

MONITORING

NC State Extension has three levels of monitoring to assure that extension specialists and educators are implementing affirmative action and civil rights policies and procedures in the assessment of needs, development, implementation, and evaluation of extension’s educational programming. In addition, processes are in place to assure that “all reasonable effort” is being pursued to identify, invite, and enhance participation of minorities and underrepresented groups on boards and committees that are critical in accomplishing the mission of NC State Extension. Following are major activities used to monitor compliance.

An annual internal county review is conducted by each County Extension Center Director (CED) and the Director of the EBCI Extension Center and submitted in the Extension Civil Rights (XCR) online system. The internal review includes but is not limited to the completion of a civil rights and language access checklist; examination of program participant parity compared to county population; examination of advisory group membership parity compared to county population; use of the nondiscrimination and accommodation statements on program announcements and materials; staff and volunteer training; accommodations and language access services requested and provided; barriers to program participation; and outreach efforts. Annual County internal reviews will be monitored by District Extension Directors (DED) as part of the CED annual performance review process.

Each DED will conduct on-site internal reviews of one-quarter of the county centers within their assigned district each year based on the published 4-year review schedule. This review provides an in-depth discussion between the district director and county center staff regarding civil rights practices. The DED will complete an online form within XCR highlighting observations and recommendations. The internal review will be closed when the district director determines the proposed actions have sufficiently been implemented.

The Civil Rights Coordinator will conduct a statewide internal review once every three years. The statewide review will look broadly at functioning of the system overall, policies and procedures, data collection processes, and training. Based on this review the Civil Rights Coordinator will revise policies or update trainings, increase communications to staff, or make other program adjustments as needed. The Civil Rights Coordinator will also monitor the XCR system and other data collection processes to ensure information is being consistently and accurately being collected.

Updated: January 2024