NC STATE EXTENSION

Extension Program and Compliance Review

2018-2021

County:

Date of Review:

District Extension Director:

County Extension Director:

This guide serves as accountability tool to ensure that County Extension offices are in compliance with civil rights and equal opportunity policies in the implementation of Extension programs, that every customer and employee is treated with fairness, equality, and respect, and that programs are inclusive and have adequate diversity. An on-site audit of each county Extension office, led by the respective District Extension Director, will occur once every four years based on the schedule below.

2018	2019	2020	2021
WEST	Cherokee Clay Graham Macon Swain	Haywood Henderson Jackson Polk Transylvania	Buncombe Cleveland Madison McDowell Rutherford	Avery Burke Caldwell Mitchell Watauga Yancey
NORTH CENTRAL	Alleghany Ashe Surry Wilkes Yadkin	Davidson Davie Forsyth Rockingham Stokes	Alamance Caswell Chatham Guilford Randolph	Durham Granville Orange Person Vance
SOUTH CENTRAL	Alexander Catawba Gaston Iredell Lincoln	Cabarrus Mecklenburg Rowan Stanley Union	Anson Montgomery Moore Richmond Scotland	Cumberland Harnett Hoke Lee
NORTH EAST	Edgecombe Franklin Nash Wake Warren	Bertie Halifax Hertford Martin Northampton	Beaufort Dare Hyde Pitt Tyrell Washington	Camden Chowan Currituck Gates Pasquotank Perquimans
SOUTH EAST	Greene Johnston Lenoir Wayne Wilson	Carteret Craven Jones Onslow Pamlico	Bladen Duplin Robeson Sampson	Brunswick Columbus New Hanover Pender

Part I: Observation

Part I should be completed by the DED as you enter and are walking around the County Extension Office during the compliance review site visit.

O-1. Is the office entrance and routing of clients set up in a way that discrimination on the basis of race, color, national origin, sex, age, or disability would not occur?	NO	YES

If no, explain:

O-2. Is office space for Extension employees arranged according to function, without regard to color, national origin, sex, age, or disability?	NO	YES

If no, explain:

O-3. Are Extension facilities accessible to disabled people?	NO	YES

If no, explain:

O-4. Where is the "And Justice for All" poster displayed? Check all that apply.

Prominently at/near entrance	In Extension conference room

In reception area	In Extension meeting room or auditorium

Other, identify location(s)

NOT DISPLAYED

Is the poster readily visible to the visiting public?	NO	YES

Part II: Staff Knowledge of Civil Rights

Part II questions should be asked of Extension employees in a group setting or to multiple employees individually to gauge the overall knowledge level of civil rights. Document responses and your overall impression of the level of knowledge.

SK-1. What does “all reasonable efforts” mean? What are examples of these efforts?

SK-2. Where can you publicize educational programs and activities to be sure that all audiences are aware of your program or activities?

SK-3. What are some accommodations you can make so your programs are accessible to disabled persons?

SK-4. What are the recruitment and membership guidelines for Advisory Leadership Councils and Committees?

SK-5. How do you file an employment discrimination complaint?

SK-6. How can an Extension client file a civil rights program complaint?

Sample Answers to Staff Knowledge of Civil Rights

When is "All Reasonable Effort" required?

The phrase "all reasonable efforts" refers to NIFA-USDA civil rights requirements pertaining to extension programming in defined geographic areas. Extension is required to use “all reasonable effort” with programming delivered to all organized groups and clubs. All reasonable effort is required when new groups are formed and is done periodically to assure that individuals living in the community where the groups/clubs meet are invited to become members. All reasonable efforts are required when a club or group is identified as not having balanced membership when entered into the Extension Reporting System (ERS). The minimum “all reasonable effort” required for county Extension staff members for any identified clubs or groups whose membership is not balanced, includes the following items:

Use all available mass media, including radio, newspaper, and television and social media to inform potential recipients, with the multi-racial communities, of the program and of the opportunity to participate.

Personal letters and fliers/publications addressed to potential recipients inviting them to participate, including dates and places of meetings or other planned activities.

Personal visits by the county Extension staff to a representative number of defined potential recipients in the geographically defined areas to encourage participation.

Where would you publicize educational programs and activities to be sure that all audiences are aware of the program or activities?

Publicize in areas/locations that are frequented by the targeted audience. To reach minority audiences

notices should be posted in minority neighborhoods and disseminated through grass roots organizations, minority churches and media that specifically reaches minorities.

What are some of the considerations involved in making your programs accessible to disabled persons?

(a) May not refuse participation by a disabled person in a service, program, or activity simply because the individual has a disability; (b) Must provide programs and services in an integrated setting, unless separate or different measures are necessary to ensure equal opportunity; (c) Must eliminate unnecessary eligibility standards or rules that deny individuals with disabilities an equal opportunity to enjoy their services, programs, or activities unless “necessary for the provisions of the service, program, or activity;” (d) Are required to make reasonable modifications in policies, practices, and procedures that deny equal access to individuals with disabilities, unless a fundamental alternation in the program would result; (e) Must furnish auxiliary aids and services when necessary to ensure effective communications, unless an undue burden would result; (f) May not place special charges on individuals with disabilities to cover the costs of measures necessary to ensure nondiscriminatory treatment; and (g) Shall operate programs so that, when viewed in their entirety, they are readily accessible to and usable by individuals with disabilities.

What are the guidelines for participation of minorities on advisory and planning groups?

The groups should represent the racial, ethnic, and gender makeup of the population.

How do you file an employment discrimination complaint?

To file a workplace-related complaint you can 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 Non-Discrimination Policy. The form can be accessed at the NC State Equal Opportunity and Equity section’s website.

How would someone file a Civil Rights Program Complaint?

Complainants have three options for filing complaints: informal complaint procedure, formal complaint procedure, and notification sent directly to USDA. Complaints can be informally resolved by an employee or County Extension Director. If a complaint cannot be resolved informally, the client should be provided with the NC State Extension Discrimination Complaint Brochure. A formal written complaint may be made with the Director of Extension. Clients may send notification of a complaint to the USDA Assistant Secretary for Civil Rights using USDA Program Discrimination Complaint Form, AD-3027, found online or at any USDA office.

Part III: Program Management

Part III should be completed by conducting interviews with the County Extension Director. Original documentation should be reviewed and noted.

PM-1. What civil rights training have Extension employees participated in during the past program year?

Does county civil rights file contain attendee records and agendas?	NO	YES

PM-2. If any Extension staff meetings in the past year included a discussion or review of civil rights and affirmative action compliance, what was the nature of the discussion?

Does county civil rights file contain meeting information (attendees, agendas, minutes)? NO	YES

PM-3. What civil rights training has been provided to leadership advisory councils, program committees, 4-H club leaders, and volunteers during the past program year?

Does county civil rights file contain attendee records and agendas?	NO	YES

PM-4. Are you aware of any Extension employee in your county that sponsors, supports, financially assists or officially participates in any conferences, conventions or meetings where participants are segregated, excluded or treated differently based on race, color, national origin, religion, handicap, or gender/sex?

If yes, explain:	NO	YES

PM-5. Do any Extension programs in your county have sex based eligibility requirements to participate?

If yes, explain:	NO	YES

PM-6. Do any recognitions, contests, or awards in Extension programs or events have sex based eligibility requirements?	NO	YES

If yes, explain:

PM-7. In order to assure that underserved audiences are aware of educational programs “all reasonable efforts” must be made to notify potential participants of program opportunities.

Provide examples of how your county office has used mailings, postings, mass media, websites, and social media to inform potential recipients of Extension programs and of the opportunity to participate.

Does county civil rights file contain examples of these efforts?	NO	YES

Provide examples of how your county office has used targeted personal communications, collaboration with other public, grass roots, and minority serving organizations, attendance at community events, and other outreach efforts to inform potential recipients of Extension programs and of the opportunity to participate.

Does county civil rights file contain examples of these efforts?	NO	YES

PM-8. Has a self-evaluation for determining program and facility accessibility for disabled audiences been conducted? Were any corrective actions identified?	NO	YES

Does county civil rights file contain the self-evaluation	NO	YES

PM-9. What steps have been taken to eliminate barriers for disabled people to fully participate in Extension programs?

Does county civil rights file contain documentation of these efforts?	NO	YES

PM-10. Has a LEP (Limited English Proficiency) 4-factor analysis been conducted?	NO	YES

Does county civil rights file contain the analysis results?	NO	YES

PM-11. What steps have been taken to ensure that LEP persons have access to the programs and services provided by Extension employees?

PM-12. Does the Extension nondiscrimination statement appear on all informational materials and program announcements released to the public?	NO	YES

Does county civil rights file contain examples of the use of the statement?	NO	YES

PM-13. Does the Extension accommodation statement appear on all and program announcements released to the public?	NO	YES

Does county civil rights file contain examples of the use of the statement?	NO	YES

PM-14. Are signed certification of non-discrimination obtained from each 4-H club and organized Extension group?	NO	YES

Does county civil rights file contain examples of these certifications?	NO	YES

PM-15. Are signed certification of non-discrimination obtained from organizations working with Extension?	NO	YES

Does county civil rights file contain copies of these certifications?	NO	YES

Part VI: Civil Rights Data Review

Review the following ERS data for the County and note areas where additional efforts are required.

DR-1. Review Civil Rights Compliance reports ERS for the past 36 months to determine if advisory councils/committees and clubs/groups are representative of the population. Identify the groups that are not in compliance.

DR-2. Review the All Reasonable Efforts reports in ERS for the past 36 months to determine if all reasonable efforts have been made to ensure sincere efforts have been made to increase participation by underrepresented groups in Extension programs.

DR-3. Review Client Contact Reports in ERS for each Agent for the past 36 months to determine if service is provided across race, ethnicity, and gender.

DR-4. Review Client Contact Reports ERS for the past 36 months by program area to determine if program participation data stratified by race, ethnicity, and gender is representative of the population of the county.