Wisconsin Department of Justice Subgrantee Civil Rights Information
As a condition of the receipt of federal grant funding through the Wisconsin Department of Justice (WisDOJ), subgrantees must comply with civil rights laws and regulations that prohibit discrimination. The following sections provide information and links to websites that will be helpful to WisDOJ subgrantees in complying with these civil rights requirements. In addition, they provide information on certifications subgrantees must complete as a condition of receiving federal grant funding through WisDOJ.
Civil Rights Training Opportunities
The US Department of Justice (US DOJ), Office of Justice Programs (OJP) has online training videos in the areas of Civil Rights, LEP and EEOP to help you understand your requirements as a subrecipient of these funds through a WisDOJ grant. You can find the training videos at https://www.ojp.gov/program/civil-rights/online-training. If you do not find the information you are looking for please contact your WisDOJ program manager for assistance.
Civil Rights Laws, Regulations, and Publications
The federal Office for Civil Rights (OCR), Office of Justice Programs (OJP) website includes information that will assist subgrantees in complying with civil rights laws and regulations. The site includes information regarding Equal Employment Opportunity Plans, the prohibition against national origin discrimination affecting persons with limited English proficiency, and other civil rights law and regulations: https://www.ojp.gov/program/civil-rights/overview
The OCR site provides an overview of specific statutes and regulations relating to civil rights and nondiscrimination, including: Section 601 of Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d; Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794; Section 901 of Title IX of the Education Amendments of 1972, 20 U.S.C. 1681; Section 303 of the Age Discrimination Act of 1975, 42 U.S.C. 6102; Section 809(c) of Title I of the Omnibus Crime Control and Safe Streets Act of 1968, 34 U.S.C. 10228(c); and Section 1407(e) of the Victims of Crime Act of 1984, 34 U.S.C. 20110(e). Synopses of these laws and related regulations may be found at https://www.ojp.gov/program/civil-rights/statutes-regulations
Limited English Proficiency (LEP)
Courts have interpreted Title VI's prohibition of discrimination on the basis of national origin to include discrimination based on English proficiency. Under Title VI (and the Safe Streets Act), recipients are required to provide LEP individuals with meaningful access to their programs and services. Providing "meaningful access" will generally involve some combination of services for oral interpretation and written translation of vital documents. LEP guidance and requirements for subgrantees of OJP Federal funds can be found at https://www.ojp.gov/program/civil-rights/limited-english-proficient-lep.
Equal Employment Opportunity Plan (EEOP) and Required Certification Process
An Equal Employment Opportunity Plan (EEOP) is a workforce report that some organizations must complete as a condition for receiving Justice Department funding authorized by the Omnibus Crime Control and Safe Streets Act of 1968. The EEOP's purpose is to ensure that recipients of financial assistance from the Justice Department are providing equal employment opportunities to men and women regardless of sex, race or national origin.
As a subrecipient of US DOJ funding, your organization may be required to submit a Certification Report or the Utilization Report portion of your plan to the Office for Civil Rights. If you are unsure of whether your organization is subject to the Civil Rights requirements of the Safe Streets Act, please refer to the EEOP FAQ https://www.ojp.gov/program/civil-rights/eeop/faqs#faq-how-can-i-tell-if-a-recipient-is-subject-to-the
The Equal Employment Opportunity (EEO) Reporting System will allow you to create your organization’s account, then prepare and submit an EEO Certification Form and if required, create and submit an EEO Utilization Report. You will also be able to access your organization’s saved information in subsequent logins.
EEO Reporting Tool Login: https://ocr-eeop.ncjrs.gov
Not every subgrantee is required to file an EEOP. Subgrantees subject to the authority of the Safe Street Act (as well as recipients of VOCA funds) must develop an EEOP if they meet all of the following criteria:
- The recipient is a state or local government agency or a business;
- The recipient has 50 or more employees; and
- The recipient has received a single aware of $25,000 or more.
The OCR website includes information about when an EEOP is required and how to develop one:
Filing A Civil Rights Complaint
The Office for Civil Rights (OCR) investigates complaints from individuals or groups who believe they have experienced discrimination from an agency that receives funding from the US DOJ. These include the Office of Justice Programs and its components as well as the Office of Community Oriented Policing Services and the Office on Violence Against Women. OCR can also investigate agencies that receive US DOJ funding from state and local goverment agencies.
Discrimination on the basis of race, color, national origin, sex, gender, gender identity, sexual orientation, religion, disability, age, or other protected status is counter to the fundamental values of the WisDOJ and prohibited by state and federal law.
If you believe that you have experienced discrimination, you are encouraged to file a civil rights complaint as soon as possible. In most circumstances, you have only one year or less from the date of the incident to do so.
Complete the Complaint Verification Form and the Identity Release Statement, found at https://www.ojp.gov/program/civil-rights/filing-civil-rights-complaint, and submit to:
Office for Civil Rights
Office of Justice Programs
U.S. Department of Justice
810 7th Street, NW
Washington, DC 20531