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 eight federal laws:

  1. Civil 11/08/20074 Title VI
  2. Civil Rights Act of 1964 Title VII
  3. Civil Rights Act of 1991
  4. Title IX, Education Amendments of 1972
  5. The Americans with Disabilities Act of 1990, Title I and V
  6. Rehabilitation Act of 1973
  7. Age Discrimination Act of 1967
  8. Limited English Proficiency — Executive Order 13166

Extension also operates under the University of Maine Affirmative Action Plan (PDF).

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 (PDF)
  • 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
  • Informing organizations and groups with which Extension cooperates of our non-discrimination provisions, and their obligation to comply with these obligations if we are collaborating to offer a program, by using this non-discrimination sign-off form and following guidelines for its use.
  • When acquiring the assurance of nondiscriminatory practices from volunteers, you may use the Standards of Behavior form (instead of the non-discrimination sign off above).
  • 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 Non-Discrimination Statement

To be included in bulletins, announcements, publications, catalogs, application forms, other recruitment materials, or other publications that are made available to students, employees, applicants or participants. If you are actively seeking participation in a workshop or event, please add the ADA statement below. When using the non-discrimination statement without the ADA statement, be sure to include a local or 800 # phone contact. Statement(s) should be no smaller than 6 point font, preferably sans serif such as Frutiger or Open Sans.

The University of Maine is an EEO/AA employer, and does not discriminate on the grounds of race, color, religion, sex, sexual orientation, transgender status, gender expression, national origin, citizenship status, age, disability, genetic information or veteran’s status in employment, education, and all other programs and activities. The following person has been designated to handle inquiries regarding non-discrimination policies: Director of Equal Opportunity, 101 North Stevens Hall, University of Maine, Orono, ME 04469-5754, 207.581.1226, TTY 711 (Maine Relay System).

The following civil rights notification can be used on postcards and may be appropriate for posters and displays. Generally, if a poster/display is informational, you may use the one-line statement below. If the poster/display is intended to encourage a person to enroll in a program, use the short form non-discrimination statement and ADA above. Please consult with Fran Sulinski.

The University of Maine is an equal opportunity/affirmative action institution.

The Americans with Disabilities Act (ADA) Notice

When actively seeking participation in a workshop or event use the short form statement and the ADA notice:

For more information or a reasonable accommodation, please contact [insert first and last name of person to contact at sponsoring unit here] at [insert telephone number or other contact information here], [insert phone number] or [insert email address].

It is helpful to suggest a date by which accommodation requests should be made. The following suggested language may be used:

If you need a reasonable accommodation, please contact [insert first and last name of the person to contact at sponsoring unit here] at [insert telephone number or other contact information here] by [insert a date two weeks or some other reasonable interval before the event]. If requests are received after this date, we may not have sufficient time to make necessary arrangements.

It is important to remember that UMaine Extension cannot refuse to accommodate someone if the request is reasonable. Do not refuse any request before speaking with the office of the Assistant Director, Fran Sulinski. 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. Remember that the person with the disability probably has the most information about what is needed for an accommodation. Most requests are generally modest; often they simply involve using ingenuity. Have a dialogue with the person needing the accommodation to find out what he or she thinks will work the best.

Each office should keep a logbook of requests for accommodations. Record the date and time of the request, what response was given to the request and the result.

UMaine Extension employees cannot refuse a request for an accommodation. Refusal to provide an accommodation is an institutional decision that must originate from the UMS office of equal opportunity. If a situation arises where agreement cannot be reached on what constitutes a reasonable accommodation, it is important to contact Fran Sulinski at fran.sulinski@maine.edu immediately. Refusal to provide reasonable accommodation may create legal liability for Extension and the University of Maine.

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 the office of the Assistant Director Fran Sulinski at fran.sulinski@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. Civil Rights Program/Planning Resources (Word) contains useful statistical information and links. 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 regardless of race, color, religion, sex, sexual orientation, including transgender status or gender expression, national origin or citizenship status, age, disability, genetic information or veteran status, and that UMaine Extension provides, upon request, reasonable accommodations to qualified individuals. Letterhead is printed with the inclusion 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 obtain names of minority farmers or landowners. Similar checks are made with other agencies to obtain potential underrepresented and underserved 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 Fran Sulinski. 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 Fran Sulinski 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.