Olmsted County Comprehensive Civil Right Plan
Effective date: 12/3/2021
Purpose:
Olmsted County has a CCRP to ensure that all eligible individuals receive equal access to program services and information.
Policy Statement:
Olmsted County’s programs are operated in a nondiscriminatory way, without regard to race, color, national origin, age, disability, sex, sexual orientation, gender identity, marital status, familial status, religion, political beliefs, creed, and public assistance status. In medical programs, sex includes sex stereotypes and gender identity under any health program or activity receiving federal funds. This CCRP also serves as a source of information for county agency staff and the general public. It sets out Olmsted County’s civil rights administrative policies and procedures, identifying key contacts within the agency and linking the reader to applicable state and federal civil rights laws and resources.
Civil Rights Contact
Olmsted County designates Julian Currie to serve as the agency’s Civil Rights Contact, agency point person on civil rights matters.
Julian Currie
Olmsted County Director of Human Resources
(507) 328-6015 (voice) or Minnesota Relay Service at 711
julian.currie@olmstedcounty.gov
Equal Opportunity Policy and Procedure
It is the policy of Olmsted County to make sure that program benefits and services are available to everyone and provided to all eligible individuals without discrimination, in compliance with civil rights laws.
This policy covers Olmsted County’s full range of services, programs, and benefits, including, but not limited to, access to information about services, eligibility determinations and intake, admission procedures and treatment. The policy applies to the agencies and providers receiving federal and state funds under contracts, licenses and other arrangements with Olmsted County. The Minnesota Human Rights Act also applies to the work of Olmsted County and those agencies carrying out its programs.
Program Accessibility for People with Disabilities
Olmsted County, and all of its services, programs and benefits, are accessible to and usable by people with disabilities, including people with hearing loss, low vision and other sensory disabilities.
To avoid disability discrimination, Olmsted County will:
Notify the public about rights and protections for people with disabilities under the Americans with Disabilities Act
Designate an ADA Contact and maintain a complaint procedure
Make sure that its buildings are physically accessible for people with disabilities
Assist individuals with disabilities to apply and qualify for benefits based on their eligibility
Provide appropriate auxiliary aids and services, including accessible formats, to ensure effective communication with people with disabilities
Provide services, programs and benefits that are accessible to and usable by qualified people with disabilities
Physical access includes:
Convenient off-street parking designated specifically for people with disabilities
Curb cuts and ramps between parking areas and the Olmsted County buildings
Level access into the first floor of the Olmsted County buildings with elevator access to all other floors
Reasonable Modifications to Policies, Procedures or Practices
Olmsted County will make reasonable modifications to its policies, procedures, or practices when necessary to avoid discrimination on the basis of disability, unless Olmsted County can demonstrate that making the modifications would fundamentally alter the nature of the services, programs or benefits.
Effective Communication and Auxiliary Aids and Services
Olmsted County will take appropriate steps to ensure that communications with people with disabilities and companions with disabilities are as effective as communications with others. To ensure effective communications, Olmsted County will provide appropriate auxiliary aids and services, including accessible formats, so that people with disabilities can receive services, programs and benefits and participate in them in the same way as people without disabilities. Auxiliary aids and services include qualified readers, writers and interpreters who convey information effectively, accurately, and impartially using any necessary specialized vocabulary.
To determine what types of auxiliary aids or services are necessary, Olmsted County will give primary consideration to the requests of people with disabilities. Olmsted County 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, Olmsted County will find another equally effective auxiliary aid or service.
Olmsted County Complaint Resolution Procedure
You have the right to equal access to services, if you are an applicant, client or member of the public trying to gain access to information and/or county services. Olmsted County has adopted an internal grievance procedure providing for prompt and equitable resolution of complaints alleging discrimination.
People receiving Supplemental Nutrition Assistance Program, or SNAP, have the option to file a discrimination complaint directly with the U.S. Department of Agriculture (USDA). See attachment E for more information.
It is against the law for anyone who works for Olmsted County to retaliate against a person who files a complaint or who cooperates in the investigation of a civil rights complaint.
Olmsted County will make appropriate arrangements to ensure that people with disabilities are provided accommodations to participate in the complaint process in an equivalent manner to people without disabilities. People with disabilities are entitled to reasonable modifications to existing policies/procedures/practices as well as effective communication under the law to complete the complaint filing process. Appropriate arrangements include, but are not limited to, providing interpreters for people who are deaf or hard-of-hearing; providing taped cassettes and accessible formats for people who are blind or have low vision; and assuring a physically accessible location for complaint proceedings. The Civil Rights Contact or designee is responsible for making these arrangements.
To file a complaint, ask for Olmsted County equal opportunity policy, complaint procedure and complaint form. Use the contact information below to help you to file your complaint. You can also review the law and regulations that outlaw discrimination in the Civil Rights Contact’s office at Olmsted County.
Complaints may be made to:
Civil Rights Contact: Director of Human Resources
(507) 328-6015 (voice) or Minnesota Relay Service at 711
julian.currie@olmstedcounty.gov
When a complaint is made to the Civil Rights Contact the following procedure applies:
1.Civil rights complaints must be submitted to the Civil Rights Contact within 180 days of the date the alleged discrimination occurred.
2.A complaint must be in writing or verbally (tape recorded) and contain the name and address of the person filing it. You should also give your telephone number or relay service number if you are deaf or hard of hearing. Give your email address if it helps get in touch with you. The complaint must state the problem or action alleged and the relief desired. If you need assistance with your complaint, the Civil Rights Contact will help you.
3.Olmsted County must investigate the complaint unless it is a SNAP Civil Rights complaint. The investigation may be informal, but it must be thorough and timely. People who have an interest in the complaint must have an opportunity to submit relevant evidence about the complaint. Olmsted County will issue a written decision on the complaint within 90 days after its filing. Olmsted County will maintain the complaint records and files for three years. Complaints about program rules are not civil rights complaints and will be resolved through a different complaint process.
4.The right of the person to prompt and equitable resolution of the complaint filed hereunder shall not be impaired by the person’s pursuit of other remedies. Utilization of this grievance procedure is not a prerequisite to the pursuit of other remedies.
5.The person filing the complaint may appeal the decision by writing to the agency’s Civil Rights Contact within 15 days of receiving the written decision. The Civil Rights Contact will issue a written decision in response to the appeal, no later than 30 days after the filing. This decision is final. – This appeal process is not the same as filing a fair hearings appeal with the Department of Human Services’ Appeals and Regulations Division.
6.Olmsted County will refer all SNAP civil rights complaints to DHS or the USDA regional office in Chicago as soon as possible after received.
7.These rules shall be construed to protect the substantive rights of interested persons, to meet appropriate due process standards and to assure that the County of Olmsted and Olmsted County complies with federal and state non-discrimination laws related to service delivery.
8.Olmsted County will submit information about the complaints that are filed with Olmsted County alleging discrimination in service delivery to the DHS Civil Rights Coordinator within 90 days of the date the complaint is filed using Attachment B enclosed with this policy.
Complaint Notification Form Usage
People filing disability complaints will use Olmsted County civil rights complaint procedure.
Olmsted County will use the Complaint Notification Form to notify DHS in writing of all service delivery discrimination complaints filed against Olmsted County and resolved on the county agency level. Olmsted County will make sure the complaint notification form is completed and sent to DHS within 90 days of the date the complaint was filed in the county, so DHS can report the complaint to the appropriate federal office. A copy of the Complaint Notification Form is located in the Appendix, Attachment B.
Associated Laws and Regulations:
Enforcement: Disability Law and Standard of Access for State and Local Government Services
Section 504 of the Rehabilitation Act of 1973 protects qualified individuals with disabilities from discrimination based on their disability in federally funded programs and services.
Title II of the Americans with Disabilities Act of 1990 (Title II of the ADA) protects qualified individuals with disabilities from discrimination on the basis of their disability when the discrimination occurs in state or local government services. An agency does not have to receive federal financial assistance to be required to comply with Title II of the ADA. An agency just has to be a state or local government entity.
County human services agencies must ensure that people with disabilities are able to use their programs and services. Disability laws set out an equal access standard for providing services. This means that individuals with disabilities are entitled to equal access to human services programs; the same standard of access that applies to people without disabilities.
A public agency must reasonably modify its policies, procedures and practices to avoid discrimination. A public agency must also take appropriate steps to ensure that its communications with individuals with disabilities are as effective as communications with others.
ADA Coordinator
Olmsted County has designated an ADA Coordinator to serve as its point person on disability matters raised by applicants, clients, and members of the public. ADA Coordinator Contact information is located on the cover page of this CCRP.
Authority, Roles and Responsibilities:
Full List of Legal Authorities
Federal:
Title VI of the Civil Rights Act of 1964 (race, color, national origin)
Section 504 of the Rehabilitation Act of 1973 (disability)
Section 508 of the Rehabilitation Act of 1973 (disability)
Title II of the Americans with Disabilities Act of 1990; State and local government services (disability)
Age Discrimination Act of 1975 (age)
Community Service Assurance Provisions of the Hill-Burton Act (health facilities receiving Hill-Burton Funds)
Section 1557 of the Patient Protection and Affordable Care Act (added sex discrimination in health care programs)
Nondiscrimination Provisions of the Omnibus Budget Reconciliation Act of 1981 (Federal Block Grants):
Title IX of the Education Amendments of 1972 (sex)
Family Violence Prevention and Services Act (race, color, national origin, age, disability, sex, religion)
Food Stamp Act of 1977
Nondiscrimination Compliance Requirements in the Food Stamp Program, Food and Nutrition Service, U.S. Department of Agriculture
Bilingual Requirements in the Food Stamp Program, Food and Nutrition Service, U.S. Department of Agriculture
FNS Instruction 113-1, Civil Rights Compliance and Enforcement – Nutrition Programs and Activities, Food and Nutrition Service, U.S. Department of Agriculture (2005)
Equal Opportunity for Religious Organizations Regulation
State:
Minnesota Human Rights Act, Chapter 363A
Related information
Civil Rights Notification Form
Civil Rights Notification Form
Full List of Legal Authorities
Federal
1. Title VI of the Civil Rights Act of 1964 (race, color, national origin)
2. Section 504 of the Rehabilitation Act of 1973 (disability)
3. Section 508 of the Rehabilitation Act of 1973 (disability)
4. Title II of the Americans with Disabilities Act of 1990; State and local government services (disability)
5. Age Discrimination Act of 1975 (age)
6. Community Service Assurance Provisions of the Hill-Burton Act (health facilities receiving Hill-Burton Funds)
7. Section 1557 of the Patient Protection and Affordable Care Act (added sex discrimination in health care programs)
8. Nondiscrimination Provisions of the Omnibus Budget Reconciliation Act of 1981 (Federal Block Grants):
• Community Services Block Grant (race, color, national origin, sex) Remaining block grants (race, color, national origin, age, disability, sex, religion)
• Social Services Block Grant
• Maternal and Child Health Services Block Grant
• Projects for Assistance in Transition from Homelessness Block Grant
• Preventive Health and Health Services Block Grant
• Community Mental Health Services Block Grant
• Substance Abuse Prevention and Treatment Block Grant
9. Title IX of the Education Amendments of 1972 (sex)
10. Family Violence Prevention and Services Act (race, color, national origin, age, disability, sex, religion)
11. Food Stamp Act of 1977
12. Nondiscrimination Compliance Requirements in the Food Stamp Program, Food and Nutrition Service, U.S. Department of Agriculture
13. Bilingual Requirements in the Food Stamp Program, Food and Nutrition Service, U.S. Department of Agriculture
14. FNS Instruction 113-1, Civil Rights Compliance and Enforcement – Nutrition Programs and Activities, Food and Nutrition Service, U.S. Department of Agriculture (2005)
15. Equal Opportunity for Religious Organizations Regulation
State
Minnesota Human Rights Act, Chapter 363A
Family Support and Assistance (FSA) Department
Olmsted County Health, Housing, and Human Services (HHH)
2117 Campus Dr. SE, Suite 200
Rochester, Minnesota 55904
(507)328-6500
Minnesota Relay Service at 711 or 1-800-627-3529
The Comprehensive Civil Rights plan is posted in the FSA lobby next to the reception desk, and on the Olmsted County website.
Purpose
As a recipient of federal financial assistance, Olmsted County Family Support and Assistance (FSA) is responsible for providing core services to assist and support Minnesota’s most vulnerable individuals and families so they can meet their basic needs and be treated with respect and dignity.
Filing Complaints with Federal Agencies
You have the option to file a discrimination complaint directly with the U.S. Department of Health and Human Services’(HHS) Office for Civil Rights for HHS programs such as the Medical Assistance, social services including child welfare services, or the Minnesota Family Investment Programs.
U.S. Department of Health and Human Services
Office for Civil Rights
Region V
233 N. Michigan Avenue
Suite 240
Chicago, IL 60601
312-886-2359 (voice)
800-368-1019 (toll free)
You also have the right to file a discrimination complaint directly with the U.S. Department of Agriculture (USDA) for the Supplemental Nutrition Assistance Program (SNAP). To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDS 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.
U.S. Department of Agriculture (USDA)
Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington, D.C. 20250-9410
fax: (202) 690-7442
email: program.intake@usda.gov
Filing complaints with State Agencies
You have the option to file a discrimination complaint directly with the Minnesota Department of Human Rights and the Minnesota Department of Human Services.
The Minnesota Department of Human Rights prohibits discrimination in public services programs because of race, color, creed, religion, national origin, disability, sex, sexual orientation, or public assistance status. Contact the Minnesota Department of Human Rights directly:
Minnesota Department of Human Rights
540 Fairview Avenue North, Suite 201
St. Paul, MN 55104
651-539-1100 (voice)
800-657-3704 (toll free)
711 or 800-627-3529 (MN Relay)
651-296-9042 (fax)
Info.mdhr@state.mn.us
The Minnesota Department of Human Services prohibits discrimination in its programs because of race, color, national origin, creed, religion, sexual orientation, public assistance status, age, disability, or sex, including sex stereotypes and gender identity discrimination that occurs in health programs or activities receiving federal financial assistance, such as Medical Assistance, MNCare, CHIP programs and insurance companies and state health insurance exchanges. Contact the Equal Opportunity and Access Division directly only if you have a discrimination complaint:
Minnesota Department of Human Services
Equal Opportunity and Access Division
P.O. Box 64997
St. Paul, MN 55164-0997
ice) or use your preferred relay service
County agencies are not permitted to investigate civil rights complaints in the Supplemental Nutrition Assistance Program (SNAP) because counties directly administer SNAP benefits. County agencies must refer SNAP civil rights complaints to DHS or the USDA regional office in Chicago. The USDA regional address is:
Civil Rights Director
Midwest Regional Office
USDA/Food and Nutrition Service
77 W. Jackson Blvd., 20th Floor
Chicago, IL 60604-3591
(312) 353-6657 (voice) or use your preferred relay service
United States Department of Agriculture Non-discrimination Statement
USDA requires that the following nondiscrimination statement be provided exactly as it is shown below:
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, religious creed, disability, age, political beliefs, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who required alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English.
This institution is an equal opportunity provider.
ADA Notice Document
Olmsted County Family Support and Assistance office will use the DHS Brochure: Do you have a disability; DHS-4133-ENG , as its ADA notice document. This notice document informs applicants, clients, and members of the public that Olmsted County does not discriminate on the basis of disability. The notice document also gives information to the public about the rights of people with disabilities under the Americans with Disabilities Act.
Olmsted County Family Support and Assistance has a copy of DHS brochure: Do you have a disability (DHS-4133-ENG) posted in the lobby next to the Family Support and Assistance reception desk.
Disability Policy Prohibiting Discrimination
The Olmsted County Equal Opportunity Policy and Procedure includes provisions which prohibit disability discrimination in human services programs. This policy is located in the Family Support and Assistance lobby.
Annual Civil Rights Training for the Supplemental Nutrition Assistance Program (SNAP)
Olmsted County Family Support and Assistance will conduct annual SNAP civil rights training for all staff who administer the SNAP program and all staff who have direct contact with the public, such as support staff, supervisors and managers.
If Olmsted County Family Support and Assistance uses DHS’ PowerPoint presentation to train staff, they will document the date of the training each year and document who attends the training. If DHS Trainlink is used, DHS will retain training records for compliance of staff.
Civil Rights Assurances of Compliance Agreements
Olmsted County and Olmsted County SNAP/MFIP providers have signed Civil Rights Assurance of Compliance agreements.
Comprehensive Civil Rights Plan Administration
Olmsted County Family Support and Assistance will:
Post a copy of its CCRP in the agency lobby where members of the public can review it and in the employee break room where staff can review it
Post the CCRP on the agency’s public website
Review the CCRP annually with ALL staff
For the benefit of applicants, clients and members of the public, prominently post in the lobby a copy of the equal opportunity policy and procedure that includes provisions prohibiting disability discrimination and a copy of its civil rights complaint procedure
Post a copy of the DHS brochure: Do you have a disability (DHS-4133-ENG) in the lobby next to the reception desk
Conduct annual SNAP civil rights training for all staff who administer the SNAP program and all staff who have direct contact with the public, including support staff, supervisors and managers. Olmsted County Family Support and Assistance will document the date of the training each year and document who attends the training, unless training is completed on DHS Trainlik site where the training documents will be retained.