Instructions for Compliance with Civil Rights Title VI




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Instructions for Compliance with Civil Rights Title VI

Kentucky Housing Corporation (KHC) has and will continue to take a proactive approach to fully implement procedures to eliminate discrimination on the basis of race, color, national origin, sexual orientation, gender identity, and marital or familial status.


In accordance with KRS 344.015, KHC developed a Title VI Implementation Plan. All organizations that receive pass-through federal funding from KHC must comply with this implementation plan. To ensure that KHC meets its compliance responsibility, procedures have been established to provide monitoring of Title VI compliance activities and complaint processing in all programs.
To meet the requirements of compliance, your organization has two options. Your organization can adopt the enclosed plan created by KHC. If you choose this option, KHC must have on file copies of your:
 Nondiscrimination Policy

 Compliance Assurance, including:



  • copy of language used in contracts to provide direct services to clients.

  • copy of language used to assure that subcontractor or vendors are clearly aware of your agency's commitment to Title VI.

If you have submitted those items within the past year, KHC already has those items on file and you need return only the Civil Rights Title VI Self Survey and the Statement of Assurance. If you have not submitted those items within the past year, you must submit those items with your completed Civil Rights Title VI Self Survey. Please note, in compliance with new federal regulations and KHC policy, all nondiscrimination policies must clearly include sexual orientation, gender identity, and marital status as protected classes. Additionally, please ensure that a local Title VI coordinator is identified in question 5 of the Self-Survey.

Full compliance cannot be achieved unless all of these items are included.
Your organization may also create its own Title VI implementation plan and submit it to KHC for approval. Most organizations have chosen to adopt the KHC plan. Regardless of which option your organization chooses, you must maintain a copy of a Title VI plan for review by the general public and any compliance organization.
If you have questions about Title VI or completing the required documentation, you may contact Karen Quinn at (502) 564-7630, extension 752. Once you have completed the above-mentioned requirements, please send them to: ESG Program Representative, KHC, 1231 Louisville Road, Frankfort, Kentucky 40601-6191.
Upon receipt of the proper documentation, KHC will certify compliance with Title VI. KHC is unable to release any federal dollars until the participating agency reaches full compliance with Civil Rights Title VI requirements.
CIVIL RIGHTS TITLE VI SELF-SURVEY
1. Date of Survey:_________________________
2. Type of Survey:  Initial  Update  Other:___________
3. Check program area:


  • HOME Investment Partnership

  • Emergency Solutions Grant (ESG)

  • Shelter Plus Care

  • Continuum of Care (CoC)

  • Section 8 Housing Assistance

  • Section 8 New Construction

  • Family Self-Sufficiency (FSS)

  • HOPE for Elderly Independence

  • Appalachian Regional Commission (ARC)

  • Housing Opportunities for Persons with AIDS (HOPWA)

4. Name of Facility/Agency: _______________________________

Street Address: _______________________________

City, State, Zip: _______________________________

County: ________________
5. Administrative Head: _______________________________

Title: ________________


6. Local Title VI Coordinator: _______________________________

Street Address: _______________________________

City, State, Zip: _______________________________

Phone Number: ________________




  1. Advisory Group or Advisory Board:

  1. What is the racial composition of the advisory group or advisory board?

Total:_____ Number of white:_____ Number of nonwhite:_____

  1. How are members selected?

___________________________________________________________

  1. What is the length of the term members serve on the advisory group or board?

___________________________________________________________

8. Nondiscrimination Policies: Does your Agency have a written policy stating that services will be provided to all persons without regard to race, color, national origin, sexual orientation, gender identity, or marital status?

 Yes  No

If yes, attach a copy (FOR INITIAL SURVEY ONLY).


9. Posters: Are posters containing Title VI information prominently displayed within the facility?

 Yes  No

a. Do these posters show the name of the Local Coordinator to whom complaints should be referred?

 Yes  No


10. Records: Are permanent records kept of all Title VI complaints?

 Yes  No


11. Complaints: If applicable, describe below any complaints received in this reporting period:


Name of Complainant

Race

Charge

Findings




















































  1. Dissemination: Is Title VI disseminated to your employees and your clients/applicants?

 Yes  No
If yes, describe how employees are informed: _____________________________________

____________________________________________________________________________________________________________________________________________________




  1. Are you confident that applicants and clients are clearly aware of their rights under Title VI, including the right to file a complaint?

 Yes  No
b. Are new employees clearly informed about their specific responsibilities to clients under Title VI?

 Yes  No

c. Are staff members periodically reoriented or refreshed on information detailing their Title VI responsibilities?

 Yes  No


If yes, state by whom and how: _____________________________________________

______________________________________________________________________________________________________________________________________________


13. Compliance Assurance: Do all contracts that provide direct services to clients contain a Title VI statement of compliance?

 Yes  No


If yes, attach a copy of the Title VI statement included in such contract (FOR INITIAL SURVEY ONLY).
14. Are you confident that each of your subcontractors or vendors, if any, are clearly aware of your agency’s commitment to Title VI?

 Yes  No


If yes, attach a copy of information used to ensure subcontractors or vendors are aware of your agency’s commitment to Title VI (FOR INITIAL SURVEY ONLY).
15. Are all physical areas (i.e., exits, waiting rooms, dining areas, restrooms, etc.) provided and used without regard to the race, color, national origin, sexual orientation, gender identity, or marital status?
 Yes  No
If no, identify the areas that are not used jointly and explain why: _____________________

____________________________________________________________________________________________________________________________________________________


TITLE VI – continued

STATEMENT OF ASSURANCE
_______________________________________

Name of Applicant (“The Applicant”)


HEREBY AGREES THAT it will comply with Title VI of the Civil Rights Act of 1964 (P.L. 88-352) and all requirements imposed by the Regulations of the U.S. Department of Housing and Urban Development, Department of Justice (28 CFR Parts 42 and 50), Kentucky Housing Corporation (KHC), and any requirements or directives issued pursuant to that Act and the Regulations of KHC, to the effect that, no person in the United States shall, on the ground of race, color, national origin, sexual orientation, gender identity, and marital status or familial status, be excluded from participation in, be denied the benefits of, or be otherwise subject to discrimination under any program or activity for which the Applicant received Federal financial assistance from KHC; and HEREBY GIVES ASSURANCE THAT it will immediately take any measures necessary to effectuate this agreement.
THIS ASSURANCE is given in consideration of and for the purpose of obtaining any and all Federal financial assistance, grants and loans of Federal funds, reimbursable expenditures, grants or donations of Federal property and interest in property, details of Federal personnel, the sale and lease of and the permission to use Federal property or interest in such property or the furnishing of services without consideration or at nominal consideration, or at a consideration which is reduced for the purpose of assisting the Applicant, or in recognition of the public interest to be served by such sale, lease, or furnishing of services to the Applicant, or any improvements made with federal financial assistance extended to the Applicant by KHC.
BY ACCEPTING THIS ASSURANCE, the Applicant agrees to compile data, maintain records and submit reports as required to permit effective enforcement of Title VI, and permit authorized KHC personnel during normal working hours to review and copy such records, books and accounts as needed to ascertain compliance with Title VI. If there are any violations of this assurance, KHC shall have the right to seek administrative and/or judicial enforcement of this assurance and suspend future assistance.
This assurance is binding on the Applicant, its successors, transferees and assignees as long as it receives assistance from KHC. In the case of real property, this assurance is binding for as long as the property is used for a purpose for which this assistance was intended. In the case of personal property, this assurance applies for as

long as the Applicant retains ownership or possession of the property. The person or persons whose signatures appear below are authorized to sign this assurance on the behalf of the Applicant.


____________________________________ ___________________________________

Date Applicant

By: ________________________________

Title of Authorized Official

_____________________________________

_____________________________________



Address of Applicant

No other funds or benefits may be disbursed under these programs unless this assurance is completed and filed as required by existing regulations.


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