5. All Reasonable Effort
UMaine Cooperative Extension employees must insure that all reasonable effort is made to reach out to involve minorities and clientele with disabilities in UMaine Extension programs and to properly record the effort. In addition to providing public notification, the following activities are regarded as a minimum effort:
- All new Extension association executive committee members, new employees, and all new volunteer leaders must be oriented to Extension’s Civil Rights/Equal Employment Opportunity (CR/EEO) and Americans with Disability Act (ADA) responsibilities.
- Extension staff should review minority data concerning their area and should plan/evaluate steps to assure that “all reasonable effort” is achieved. Give particular emphasis to information related to total population by race, agriculturally related data by race and sex, types of enterprises generating economic activity and indications of individual and family well being. The Department of Justice has indicated that “all reasonable effort” is fulfilled when there is: a) extensive use of mass media; b) personal telephone calls or written communication to potential minority or handicapped clientele; and c) personal contact by county staff members with a representative number of potential recipients.
- County/specialist unit annual civil rights plans should reflect special efforts that will be planned for the purpose of reaching minority and handicapped clientele.
- News releases for UMaine Extension educational programs should state that they are open to the public regardless of race, color, religion, sex, sexual orientation, genetic information, national origin or citizenship status, age, disability or veterans status, and that Extension provides, upon request, reasonable accommodations.
- The And Justice for All poster should be posted prominently at all offices, summer camps and major function rooms, and included in program materials when the program setting does not include meeting in a conference room (e.g., home visits).
- The USDA requires us to annually have a representative of a group we work with on an ongoing basis (e.g., county Extension homemaker groups, 4-H Leaders Association or 4-H club, agricultural producers group, master gardeners, etc.) sign a statement stating that the group or any of its members will not discriminate against any individual who wants to use Extension’s services. The signed statement is to be annually updated and kept in your office civil rights file.
- Each county/specialist unit should maintain a CR/EEO file for filing related regulations/notices, etc. and for each employee to record contacts and CR/EEO happenings.
- Limited English Proficiency Expectations
Limited English Proficiency guidelines were established through Executive Order 13166 by President Clinton to address the problem of ethnic groups that were eliminated from meaningful access to Extension programs because they could not read forms, policies or public notices.
The Department of Justice guidance suggests applying four factors to make an assessment and plan how to “reasonably” address barriers posed by language.
- The number or proportion of LEP persons in target or eligible population
- Frequency of contact (daily, monthly, occasional, etc.)
- Nature and importance of program or activity (“life and death” vs. general or extracurricular information)
- Resources available to implement LEP and costs (small organization vs. large one; and, overall budget and resources of institution)
Ultimately the goal of providing program materials and public notification in a second language is to achieve “meaningful access” for a proportionally significant population while considering the “importance” of the information.
All program staff are expected to know and analyze the size of their target population to make a determination about whether the size of the target population with Limited English Proficiency is significant. Staff should take steps to provide meaningful access in consultation with the Assistant Director.