Comprehensive Civil Right Plan

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: 
Julian Currie
Olmsted County 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:

Attachments
Civil Rights Complaint Notification Form
Limited English Proficiency Plan
State-County Civil Rights Assurance of Compliance
Departmental Specifics