Section 3.5 Civil Rights/Equal Employment Opportunity Guidelines

UMaine Extension programs must be open and accessible to all.

The University of Maine Cooperative Extension Civil Rights/Equal Opportunity Program has its legal basis in federal law:

The Public Notification Plan

UMaine Extension’s Public Notification Plan is the process by which the public is advised of Extension programs, the requirements for non-discrimination, and the availability of reasonable accommodations for those needing them. The elements of the plan are as follows:

Display of the And Justice For All poster and Title IX poster
Use of the University’s Non-Discrimination Statement in letters, newsletters, and publications
Use of the University’s ADA notice about accommodations on forms, applications, program announcements and brochures
Establishment of outreach programs and “all reasonable efforts” at the local level to ensure that all persons, especially those who previously may not have participated fully, know about the availability of and effective use of USDA program services, and are encouraged to participate
When acquiring the assurance of nondiscriminatory practices from volunteers, you may use the Standards of Behavior form.
Use of inclusive, non-sexist language and non-discriminatory language, photos and graphics to convey the message of equal opportunity in all programming
Provision of materials in alternative means of communication (Braille, large print, audiotape, etc) upon request.

UMaine Extension Non-Discrimination Notices

The following nondiscrimination notices reflect the University of Maine Cooperative Extension’s commitment to equal opportunity, accessibility, and compliance with federal law, U.S. Department of Agriculture National Institute of Food and Agriculture (USDA NIFA) requirements, and University of Maine System policies. Two versions of the notice are provided, and either the long-form or short-form version must be used, as required, based on the specific context and criteria outlined below.

Long-form Nondiscrimination Notice

University of Maine Cooperative Extension is an equal opportunity institution and provider committed to fostering a nondiscriminatory environment and complying with all applicable nondiscrimination laws. Consistent with State and Federal law, UMaine Extension does not discriminate on the basis of race, color, religion, sex, sexual orientation, transgender status, gender, gender identity or expression, ethnicity, national origin, citizenship status, familial status, ancestry, age, disability physical or mental, genetic information, veterans or military status, income derived from a public assistance program, political beliefs, reprisal or retaliation for prior civil rights activity, in employment, education, and all other programs and activities.

The University of Maine System provides reasonable accommodations to qualified individuals with disabilities upon request. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the UMaine ADA Coordinator or contact USDA through the Telecommunications Relay Service at 711 (voice and TTY). Additionally, program information may be made available in languages other than English.

If you believe you have experienced discrimination or harassment, you are encouraged to contact the System Office of Equal Opportunity and Title IX Services at 5713 Chadbourne Hall, Room 412, Orono, ME 04469-5713, by calling 207.581.1226, or via TTY at 711 (Maine Relay System). For more information about Title IX or to file a complaint, please contact the UMS Title IX Coordinator at www.maine.edu/title-ix. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at www.usda.gov/oascr/how-to-file-a-program-discrimination-complaint and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Mail Stop 9410, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov.

The long-form nondiscrimination notice must be displayed in a font size no smaller than 8 points in both print and online formats. It must be used for the following:

Publications and other public-facing documents exceeding four pages
A nondiscrimination slide in public education presentations delivered on behalf of UMaine Extension
Hiring and recruitment materials
Included or clearly linked within online course platforms (e.g., syllabus or course information pages)
Extension websites, including event and course registration pages, must include either the long-form nondiscrimination notice or a persistent footer link labeled “Nondiscrimination Notice” linking to the long-form nondiscrimination notice (extension.umaine.edu/nondiscrimination).

Short-form Nondiscrimination Notice

University of Maine Cooperative Extension is an equal opportunity institution and provider committed to nondiscrimination. For more information, visit extension.umaine.edu/nondiscrimination.

The short-form nondiscrimination notice must be displayed in a font size no smaller than 8 points in both print and online formats. It must be used for the following:

Postcards and rack cards
Single- and double-page flyers, including brochures
Newsletters (printed, digital, and email)
Academic posters for display
Social media “About” sections, where available
A visual slide at the end of video recordings
A spoken and captioned statement at the end of audio or video recordings

Reasonable Accommodation Notice

A reasonable accommodation or modification is a change that enables a qualified individual with a disability to fully participate in and enjoy an entity’s programs or activities. However, accommodations are not required if they would fundamentally alter the nature of a program, service, or activity, or impose undue financial or administrative burdens on the entity.

If reasonable accommodation is needed, please contact LOCAL NAME, PHONE, EMAIL by [a date with reasonable interval before the event, if applicable].

The reasonable accommodation notice must be displayed in a font size no smaller than 8 points in both print and online formats. It must be used whenever we are inviting participation, including:

Notification of education events including flyers, social media event posts, etc.
Registration websites
Online education materials such as micro-credentials or asynchronous trainings

Responding to Accommodation Requests

It is important to remember that UMaine Extension cannot refuse to accommodate someone if the request is reasonable. Do not decline any request before speaking with Civil Rights Coordinator Alisha Targonski. Requests may include large print, materials in another language, a sign language interpreter, etc. Please document all accommodations made in the local civil rights file.

It is also important not to make assumptions about needed accommodations. The person with the disability often has the best understanding of what is needed. Most requests are generally modest and may simply involve some ingenuity. Have a dialogue with the person requesting the accommodation to determine what will work best.

Each office should keep a logbook of accommodation requests. Record the date and time of the request, the response provided, and the outcome.

UMaine Extension employees cannot refuse a request for an accommodation. Decisions not to provide an accommodation are institutional and must come from the UMS Office of Equal Opportunity. If a situation arises where agreement cannot be reached on what constitutes a reasonable accommodation, contact Alisha Targonski at alisha.targonski@maine.edu immediately. Failure to provide a reasonable accommodation may create legal liability for Extension and the University of Maine.

Standards for Serving Limited English Proficient (LEP) Audiences

In order to comply with Title VI nondiscrimination law and the corresponding legal framework for language access accountability, UMaine Extension commits itself to the following set of organizational standards:

Free language support services for LEP audiences

UMaine Extension will provide language support services such as translation and interpretation at no cost to the intended beneficiary of such services.

Public notification of language support services

UMaine Extension will provide public notification about the free and rightful access LEP audiences have to translation and interpretation services as a part of our organizational activities. Public notification includes providing information in multiple languages as applicable.

Complaint Procedure

UMaine Extension has three complaint procedures available for clientele use. The first is listed on the “And Justice For All” poster. This involves direct written communication with the secretary of agriculture. The second procedure is part of the official UMaine non-discrimination statement and involves directing questions and complaints to the director of equal opportunity and diversity at the university on the Office of Equal Opportunity’s Complaints page. The third method is listed below:

Procedure For Handling Complaints Of Discrimination In Violation Of Title VI Of The Civil Rights Act Or Title IX Education Amendments

Listen carefully to the complaint (if the complaint can be rectified to the client’s satisfaction, the next steps are not necessary).
Ask for the complaint in writing, or assist the client to write the complaint.
Write down a statement of the circumstances of the complaint with as much detail as possible, including date, place, who was involved, specific circumstances, and the specific way in which the complainant feels his or her rights were violated.
Read the statement back to the complainant and ask for the statement to be signed.
Notify Civil Rights Coordinator Alisha Targonski at alisha.targonski@maine.edu immediately and send a copy of the complaint with additional explanatory details. The complaint will be forwarded to UMaine’s Office of Equal Opportunity and to the Civil Rights Division of National Institute of Food and Agriculture (NIFA) USDA.

All Reasonable Effort

UMaine Extension employees must ensure that all reasonable effort is made to reach out to involve underrepresented and underserved community members including clientele with disabilities in Extension programs and to properly record the effort. In addition to providing the notices above, the following activities are regarded as a minimum effort:

Programming:

1. All new Extension Association executive committee members, new employees, and all new volunteer leaders must be oriented to UMaine Extension’s Civil Rights/Equal Employment Opportunity (CR/EEO) and Americans with Disability Act (ADA) responsibilities.

2. Extension staff should review census data concerning their area and should plan/evaluate steps to assure that “all reasonable effort” is achieved to reach audiences protected by non-discrimination policies and laws. 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 underserved and underrepresented audiences including disabled clientele; and c) personal contact by county staff members with a representative number of potential recipients. Resources to assist in the demographic profile of our communities are the United States Census American FactFinder website and the United States Census Bureau QuickFacts website.

3. County/specialist unit plans of work should reflect special efforts that will be planned for the purpose of reaching underserved and underrepresented audiences including disabled clientele.

4. Program announcements and brochures should state the program is open to the public and UMaine Extension provides, upon request, reasonable accommodations to qualified individuals. Letterhead is printed with the nondiscrimination statement. Printed material that actively seeks members, participants or beneficiaries of Extension services, programs or activities must contain the full UMaine System Non-Discrimination Statement. The “And Justice For All” poster should be posted prominently at all offices, summer camps and major function rooms.

5. All new homemaker groups and 4-H clubs should clearly delineate the geographic boundaries of their units. Established groups and clubs are encouraged to delineate their boundaries.

5.5. 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 Non-Discrimination Sign-Off Form is to be annually updated and kept in your office civil rights file.

Failure for group representatives to annually sign the statement may result in Extension’s inability to serve that group according to USDA civil rights policy.

Extension is also a department of the University of Maine which has more inclusive language in its non-discrimination statement than that of the USDA. Extension volunteers, in their orientation to Extension and as part of any volunteer training they receive, are expected to comply with the UMaine statement found in this section as representatives of the University in the community.

Should you have any questions about the statements or procedures for ensuring Extension volunteer group compliance with federal and UMaine non-discrimination policies, please contact your supervisor. Our intent is to work with community groups whose membership and educational activities are open to anyone without discrimination based on the criteria outlined in the USDA and university statements.

The USDA statement is to be signed annually and kept in the county office civil rights file. To print the form, go to Non-Discrimination Statement to be Filed in Civil Rights Folder.

6. County staff should periodically check the Census of Agriculture and connect with local USDA offices to seek out potential community partners and clientele.

7. Minutes of meetings in which CR/EEO efforts/training may be recorded should be kept, i.e., staff meetings, executive committee meetings and all advisory committee meetings.

8. 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. Please see Civil Rights File Contents for more information. When collecting contact demographic data, please utilize program forms such as the 4-H enrollment form or the Equal Opportunity for All Survey (Word). When clients have the option not to complete the form, the program staff member may augment the demographic data collected through their visual inspection of the attendees. The “Equal Opportunity for All” form lists the basic civil rights categories requested by our federal partners and may be tailored to include other groups covered by non-discrimination policy. This should be done in consultation with Alisha Targonski. The civil rights file should be kept up-to-date, and all pertinent information logged locally as well as in the planning and reporting systems. The log of accommodation requests and accommodations provided should be kept in the local civil rights file as well. Accommodations can be anything the programmer did to assist an attendee to fully participate given some limitation they were experiencing. When in doubt it is better to record what was done than to determine it was not meaningful or significant. You may also contact Alisha Targonski with questions.

9. CR/EEO success stories should be reported on Plugged-In to meet the reporting deadline.

10. UMaine Extension offices should maintain a procedure for handling alleged discrimination. Each employee should be familiar with the complaint procedure and be able to handle a complaint promptly and courteously.

11. County civil rights coordinators should periodically review with all employees Extension responsibilities for CR/EEO requirements with regard to the following:

12. Internal reviews of Extension county and campus units will take place regularly with each office to be reviewed periodically as determined by Extension’s civil rights officer.

13. Staff who do not comply with UMaine Extension’s civil rights expectations may be subject to disciplinary procedures.