Affirmative Action/ Civil Rights Compliance Training

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Civil Rights Compliance Instructions

2023 Affirmative Action/Civil Rights Compliance Trainings

• Defining Clientele and Affirmative Action Planning – Aug. 8, 2023  
  How-to define clientele groups, strategies for collecting baseline data and affirmative action goal examples. Links to
  training recording and Choose Your Own Adventure activity: programmatic examples

• Improving All Reasonable Efforts and Engagement with Diverse Audiences – Aug. 15, 2023  
  Programmatic strategies to conduct All Reasonable Effort, how to demonstrate compliance through documentation, collecting and reporting race/ethnicity/gender using self-identification forms, strategies to successfully reach and engage diverse audiences to achieve parity. Links to
  training recording and Choose Your Own Adventure activity: fact sheets

Contents

I. Background
II. Establishing baseline – Instructions for race and ethnicity
III. Collecting Extension Activity participants’ race and ethnicity
IV. Self-identification form templates
V. Aggregating and reporting Extension Activity contacts’ race and ethnicity
VI. Statewide Program instructions
VII. County Director/Supervisor roles
VIII. Stop-use of visual identification announcement, July 30, 2021
IX. UC ANR's Gender and Lived Name - Humiston Memorandum January 21, 2021
X. Civil Rights Compliance Frequently Asked Questions

I. Background

Civil Rights Compliance is about ensuring that University of California Agriculture and Natural Resources (UC ANR) is serving all Californians and who we serve reflects the race, ethnicity, and gender diversity of California’s population. Project Board aims to provide academics with an intuitive tool for capturing the Civil Rights Compliance information we are required to document Extension efforts with external audiences, ensuring that UC ANR does not discriminate. Collecting and reporting Civil Rights Compliance is not an exact science. This document provides guidance on how to capture this information to the best of our ability.

As a recipient of federal funds, UC ANR is required to collect race, ethnicity, and gender data to determine how effectively programs are reaching eligible persons and beneficiaries and to monitor compliance with federal laws and regulations.

The U.S. Office of Management and Budget issued revised standards for collecting and reporting race and ethnicity data. As a result, UC ANR includes this new race and ethnicity reporting information in Project Board in order to maintain compliance with federal regulations.

The demographic categories create a clear separation of race and Hispanic/Latino ethnicity and provide an additional race category.

Ethnicity:

• HISPANIC OR LATINO: a person of Cuban, Mexican, Chicano, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race.
• Not Hispanic or Latino.

Race:

• AMERICAN INDIAN OR ALASKA NATIVE: a person having origins in any of the original peoples of North and South America (including Central America), and who maintains tribal affiliation or community attachment.
• ASIAN: a person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.
• BLACK OR AFRICAN AMERICAN: a person having origins in any of the black racial groups of Africa.
• NATIVE HAWAIIAN OR OTHER PACIFIC ISLANDER: a person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
• WHITE: a person having origins in any of the original peoples of Europe, the Middle East, or North Africa.

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II. Establishing baseline – Instructions for race and ethnicity

Important new information: Academics are not required to create clientele groups, identify baseline information, or report contacts for audiences that are internal to ANR (i.e., staff and academics). Additionally, contacts and activities that are already being reported in other statewide program online systems do not need to be duplicated in Project Board; see below Section VI. Statewide Program instructions for Civil Rights Compliance in Project Board.

Clientele group baselines are created using data from the U.S. Census, AgCensus, EdData and other available sources. Establishing baseline often involves pulling together multiple sources, talking to people in the field, or aggregating multiple counties to reflect multiple county assignments into one clientele group. It is important to document how you formed your baseline given that there are so many ways baseline can be established in University of California Cooperative Extension. It is preferred that you lump rather than split clientele groups whenever possible to create fewer groups. If you are concerned about lumping groups that are too different in demographic makeup, you may keep them separated. For more information about establishing clientele groups and baseline in general, please contact your County Director or immediate supervisor. The remaining instructions below are specific to race and ethnicity.

Creating a new clientele group baseline in Project Board:

• First, complete the Hispanic/Latino baseline by providing the estimated number of Hispanic/Latino individuals in the “Hispanic/Latino” ethnicity category. Then put the remaining individuals in the “Not Hispanic/Latino” category or undetermined category. The numbers in all three ethnicity categories should equal your total baseline.
• Second, complete race totals. If you use sources like U.S. Census and AgCensus that collect race and ethnicity information as separate questions, then entering in the data for race and ethnic groups in Project Board can be done without needing to rearrange the data. However, if you use sources like EdData that combine the race and ethnicity categories as one question, then enter the same total number of individuals in the “Hispanic/Latino” ethnicity category in the “Race not listed above” or “undetermined” race category, and do not count any of these individuals again for any other race. Proceed with inputting numbers into each race category. The numbers in all race categories should equal your total baseline.

Update your clientele group baseline if you know that the demographic makeup of the populations you serve has changed (i.e., if you notice or hear from other sources that there have been increases or decreases in the racial/ethnic makeup of population served). If you are only using census data, update when new census data is available.

Note: CASA clientele groups were imported into Project Board and baselines were converted using these guidelines. Please review and revise any imported clientele groups as needed.

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III. Collecting Extension Activity participants’ race and ethnicity

Participants or recipients of Extension Activities are considered “clientele contacts.” Extension Activities include extending knowledge and information to both individuals (such as by providing email and telephone technical assistance) and groups (such as through hosting meetings and presenting talks at external meetings). Race, ethnicity, and gender data should be collected from clientele contacts when a significant, educational, two-way exchange occurs. There is one method in which UC ANR academics and staff can obtain the race and ethnicity of Extension Activity participants: Ask individual to self-identify. (ANR resource: See section IV for self-identify half-page questionnaire).

Self-Identify: Individuals must first self-identify as Hispanic/Latino or not Hispanic/Latino, regardless of their racial background. Then, individuals select all race categories that apply to them (if two or more categories are selected, they are reported into Project Board as “more than one race”). To reduce confusion, you may tell Hispanic/Latino individuals that if they select yes to Hispanic/Latino, they may select “Race not listed above” for the race question.

When computing the total participation at an event, gaps from participants who declined to state or chose not to complete the self-identify form/poll may be reported in the "undetermined" demographic categories. More information on reporting audience attendance is in the Activities section of the user manual.

U.S. Office of Management and Budget policy information: Self-identification using two separate questions is the preferred method for collecting data on race and ethnicity. The collection of greater detail is encouraged; however, any collection that uses more detail shall be organized in such a way that the additional categories can be aggregated into these minimum categories for data on race and ethnicity.

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IV. Self-Identification form templates

If you are associated with a Statewide Program that provides self-identify forms and reporting systems, please continue to use those forms and processes.

Half-page form: UC ANR's Office of Diversity and Inclusion provides this half-page questionnaire in MS Word, which also lives on the Project Board Help website, and can be printed for in-person events. This questionnaire is also available in Spanish. 

Qualtrics template: This template has also been created as a sample Qualtrics survey for collecting REG data and lives in the ANR Qualtrics templates library. This google doc includes instructions on how to create a Qualtrics survey using an ANR Template.

Zoom poll: One academic suggests using Zoom polls in the beginning or middle of a meeting to collect race, ethnicity, and gender data from participants
Watch a training video (9 min. 18 sec.)
Use this template to build your questions and script.

End of session survey: A very short post-event survey that measures outcomes, collects demographic information using open-ended race/ethnicity and gender questions, and solicits suggestions. Designed by Gerry Spinelli and approved for others to use.
Download PDF in English: San Diego Nursery and Floriculture Program Impact Evaluation
Download PDF in Spanish: Evaluación de impacto del Programa de Viveros y Floricultura de San Diego
Watch a training video about this survey and how to analyze REG data (12 min. 33 sec.)

V. Aggregating and reporting Extension Activity contacts’ gender, race, and ethnicity

After collecting participants’ race and ethnicity information, academics aggregate gender, ethnicity, and race totals and report them into Project Board via an Extension Activity type. Gender, ethnicity, and race totals must equal the total number of participants in that Extension Activity.

Tips/Examples:

• If a person self-identifies as Hispanic/Latino and Asian, this individual is reported in the “Hispanic/Latino” ethnicity category and the “Asian” race category.
• If a person self-identifies with multiple races, report this individual in the “More than one race” race category.
• If an individual self-identifies as "Hispanic/Latino" and does not respond to the race question, they may be reported in the  "undetermined" race category.
• Any individual who chooses not to self-identify should be reported in the "undetermined" race, ethnicity, and gender categories. This way, you are also reporting your total reach or attendance.

Important new information: If the audience of your Extension activity is internal to ANR (i.e., staff and academics), you do not need to report the demographic breakdown of your contacts. Additionally, if the audience is already being reported in another statewide program’s online system, it does not need to be reported again in Project Board; see Section VI. Statewide Program instructions for Civil Rights Compliance in Project Board.

NEW resource Dec. 2023: All significant educational exchanges with youth must be reported in 4-H online - Did you know that all significant educational exchanges with youth must also be reported into 4-H online as group enrollment? See this 4-H handout for more information: UC ANR Youth Educational Reporting 10.27.2023 FINAL

VI. Statewide Program Instructions for Civil Rights Compliance in Project Board

Civil Rights Compliance analysis is conducted by ANR Affirmative Action at the individual academic level using information entered into Project Board as well as at the statewide program level by county using their respective online systems.

UC 4-H, UC CalFresh Nutrition Education Program, California Naturalists, Expanded Food and Nutrition Education Program (EFNEP), UC Master Food Preserver, and UC Master Gardener Statewide Programs provide specific self-identify forms, processes, and online reporting systems. Please continue to use the documents and procedures as indicated by affiliated statewide programs. The general guidelines below describe the information that should be entered into Project Board and efforts have been made to streamline and reduce duplicative data entry when possible. Detailed instructions for each statewide program are under development.

Currently only academics can enter information into Project Board. Staff use of Project Board will not be available until future phases.

What Civil Rights Compliance information should be entered into Project Board by CE academics affiliated with statewide programs?

• All Reasonable Effort (A.R.E.) Activities conducted by the CE academic.
• Please note in the “description” field that these are conducted by you.
• These will be considered in your individual Civil Rights Compliance analysis.
• A.R.E. Activities conducted by staff/volunteers/partners for all statewide programs except 4-H and Master Gardener, who use an annual survey to collect A.R.E.
• Please note in the “description” field that these are conducted by staff/volunteers.
• These will be considered in the statewide program’s Civil Rights Compliance analysis.
• Extension Activities that are co-delivered by a CE academic and staff/volunteers.
• The CE academic reports the activity information into Project Board and the staff/volunteers report both activity information and demographic breakdown of participants into their statewide program’s reporting system.
• OMIT demographic breakdown of participants in Project Board since staff/volunteers will be providing the same information in the statewide program’s reporting system.
• Extension Activities delivered only by the CE academic directly to Extension clientele, including demographic breakdown of participants.
• Optional: Extension Activities delivered only by staff/volunteers.
• Per the E-Book, it is highly recommended that academics summarize these activities in the program summary narrative. Only list activities where significant intellectual input was provided. These will be exported in a separate table from those personally delivered. Also include your role in these activities that your staff or others delivered.
• OMIT demographic breakdown of participants in Project Board since staff/volunteers will be providing the same information in the statewide program’s reporting system.

What is the difference between All Reasonable Effort (A.R.E.) Activities and Extension Activities?

A.R.E. Activities are methods that can be taken to recruit new members and adult volunteers in the community to come to an event. They are entered by academics into Project Board using one of the A.R.E. Activity types.

Extension Activities provide a learning experience or significant educational exchange to clientele. Extension Activities conducted by volunteers/staff/partners should be reported in the statewide program’s online reporting system.

What do I do if the event does not fit within one of the categories in my statewide program’s reporting system?

Most events should fit within the statewide program’s existing reporting system categories. However, A.R.E. Activities do not fit within the statewide program’s system categories and should be entered into Project Board; use the description field to indicate if the A.R.E. Activities were conducted by staff, volunteers, or the academic themselves.

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VII. County Director/Supervisor roles in relation to Civil Rights Compliance

Download "Cheat Sheet" (from UC ANR's Office of Diversity and Inclusion website)

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VIII. Stop-use of visual identification announcement, July 30, 2021

To: All academics required to report civil rights compliance in Project Board [staff employees should consult with their supervisor or statewide program for instructions]

From: The Office of Diversity & Inclusion

RE: The collecting of race, ethnicity, and gender (REG) data for Extension programs

In accordance with federal regulations, UC ANR is required to solicit race, ethnicity, and gender (REG) data from the members of the public who participate in extension activities. This practice helps UC ANR to 1) analyze whether the audiences we reach represent the diverse population of California and 2) allows us to demonstrate that we are not discriminating in our program delivery practices. Visual estimation of REG makeup of audience members who declined to self-identify was a long-standing practice within UC ANR and a practice formerly found to be satisfactory in civil rights reviews. However, as a result of UC ANR’s recent re-examination of how to collect REG data and clarifying directives from the U.S. Department of Agriculture, National Institute of Food and Agriculture (NIFA), UC ANR will be discontinuing visual identification as a method to collect REG data. (Those interested may watch a NIFA training video that outlines their directives concerning Cooperative Extension’s civil rights obligations – including the disallowing of visual identification of participants -- at this link: NIFA Equal Opportunity and Civil Rights Equitable Distribution Training - YouTube -- their discussion specifically of REG data collection begins at the 26:00 minute mark.)

Immediate Changes

Self-identification will now be the only method to solicit REG data and UC ANR has developed standard language to request the data. Below is a summary of guidance from USDA NIFA and UC ANR for implementing this change:

• Download and use this half-page questionnaire in MS Word, which lives on the Project Board Help website, or you may adapt this sample Qualtrics survey to collect REG information from members of the public.
• You may use these REG questions and response categories in Zoom polls.
• You may also ask REG questions in an open-ended response format (i.e. where the participant writes in their responses rather than selecting choices from a list -- see first two questions of this example survey). With such a method, you will have to code each response into the REG categories, then aggregate and report them in Project Board.
• To help encourage individuals to self-identify, explain to them why you are collecting the information. Sample: “The following information is optional. It is confidential. It is requested to help us document that UC Cooperative Extension is extending services and benefits to everyone who is interested and does not discriminate.”
• It is acceptable, though not preferred, to add these REG questions to registration forms if it is the only feasible way of collecting REG data.
• If you received self-identified REG data from partners (e.g., schools) you may still continue to use that data as long as the data reflects your actual participants.
• Making a guess about REG from observing an individual’s name is no longer an acceptable practice.
• For contacts who choose not to self-identify or when it is not feasible to collect REG data, those individuals should still be reported as contacts in Project Board in the undetermined race, ethnicity, and gender categories. USDA NIFA has clarified that institutions will not be penalized for individuals who choose not to self-identify their REG; our job is to ask participants to self-identify. Compliance can still be achieved by conducting and reporting All Reasonable Effort. Maintaining a viable corrective action plan for groups that are out of parity (assuming self-identification) is also important.
• It is important to report in Project Board the total contacts reached. To do this, aggregate the number of individuals with unidentified REG and report them in the undetermined categories.
• Note that some UC ANR statewide programs may have their own templates and procedures for collecting and reporting this data.

As mentioned above, UC ANR had previously advised that event hosts could use visual identification to record REG data for clientele who decline to self-identify; i.e., capturing the information by looking at a group of people and making one's best guess. Visual identification was considered a secondary option that could be implemented when the preferred method of self-identification by audience members was not feasible or when the audience members declined to self-identify. USDA NIFA clarified, however, that visual identification is not an acceptable method for capturing REG data. 

UC ANR personnel are required to discontinue using visual identification to collect REG data. This change is effective immediately, and the expectation is that it will be fully implemented by December 2023.

What are we going to do?

UC ANR leadership recognizes that this may be a significant change in past practice for some. Please consider attending a Zoom technical assistance drop-in every last Tuesday in August-October 2021 from 2-3:30PM.

Zoom Meeting Link: https://ucop.zoom.us/j/5109870027 Join audio by computer or by phone: 646-558-8656 (meeting ID is 510 987 0027)

--- David White, Office of Diversity and Inclusion

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Sources

• UC ANR Office of Diversity and Inclusion website, see Training section: https://ucanr.edu/sites/anrstaff/Diversity/Affirmative_Action/
• Notice of Intent to Revise a Currently Approved Information Collection. Federal Register, vol. 81, no. 39. February 29, 2016 (pages 10211-10212).
• New Standards for Collecting and Reporting Race and Ethnicity Data for the National Reporting System. U.S. Department of Education National Reporting System Tips.
• USDA NIFA December 2020 webinar, Equal Opportunity and Civil Rights Equitable Distribution Training: https://www.youtube.com/watch?v=E0hmkHAu-jI 

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IX. UC ANR's Gender and Lived Name - Humiston Memorandum January 21, 2021

Five gender options should be provided: Woman, Man, Nonbinary, Gender Identity Not Listed, and Prefer Not to State.

Humiston Memo Gender Selection Signed

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Civil Rights Compliance Frequently Asked Questions

 1) What if a clientele group includes individuals AND organizations? Can they be lumped into one group?

No. You will have to create and report against separate clientele groups for individuals and for organizations.

2) If an Extension Activity is with a “one time” clientele group, and not with an ongoing clientele group, do I add the clientele group for just a one-time activity? A “one time” clientele group could mean a group in another county to which you are not assigned, or a different type of clientele in your county that you don’t typically serve.

No. Instead, you may do one of the following:

• If the "one time" clientele group is similar to one of your existing clientele groups, go ahead and link that Extension Activity to that existing clientele group. Example: If you are asked to conduct an Extension Activity in another part of the state (not one of your assigned counties), you can link to one of your existing clientele group.
• Utilize a non-Extension activity type, such as "Public Service" or "Evidence of Professional Competence." You do not need to link these activity types to a clientele group.

3) How do I report my contacts?

• Click on Activities in the Project Board menu and then the blue Add Activity icon.
• Select the type of activity through which you made your contacts.
• At the bottom of the activity form, you see the field “Clientele group” – if you click on it, you can select one of your existing clientele groups.
• Select one of your clientele groups, then the form will expand (scroll down) and you will be able to report your contacts by ethnicity, race, and gender.
• When you click save, these contacts will add to the descriptive statistics of each clientele group!
• Tip: You do not need to report the demographic information of contacts if they are a) internal to ANR (staff, academics, volunteers) or b) already reporting in another statewide program reporting system (4hOnline, PEARS, WEBNEERS, VMS, etc.). If your clientele includes one of these, you can click the "hide" button on the "audience attendance" section of any Extension Activity form.
• NEW resource Dec. 2023: All significant educational exchanges with youth must be reported in 4-H online: Did you know that all significant educational exchanges with youth must also be reported into 4-H online as group enrollment? See this 4-H handout for more information: UC ANR Youth Educational Reporting 10.27.2023 FINAL

4) How do I report my All Reasonable Efforts (A.R.E.)?

• Click on Activities in the Project Board menu and then the blue Add Activity icon.
• Select one of the All Reasonable Effort (A.R.E.) activity types, listed on the bottom left corner of the pop up window.
• Use the description field to qualitatively describe your use of that A.R.E. method to reach target clientele. Please lump, rather than split. For example, you can create one Mass Media Effort activity record that states that you sent monthly announcements through your social media inviting new clientele to your workshops accounts, rather than creating 12 Mass Media Effort records.
• As a reminder, to be in compliance by A.R.E., an individual must use and report three of the four A.R.E. types for the year. The four types are: individual efforts, mass media efforts, promotional material efforts, and personal letter efforts. Definitions are provided in the this user manual section on activity types.

5) I am affiliated with a statewide program that already has its own reporting system for clientele contacts (4hOnline, WebNEERS, PEARS, VMS). If I am not supposed to duplicate reporting my contacts in Project Board, how will show my reviewers the attendance of my Extension activities?

Step 1 - In Project Board - Extension Activity forms, leave audience attendance blank (tip: Click "Hide" on that part of the form) when the clientele are already reporting in another statewide program reporting system. This will save you time because if you enter it in Project Board, you’ll have to provide audience by demographic breakdown (which is unnecessary because we already get that from the other reporting systems).

Step 2- When you export your dossier to MS Word, fill in the blank attendance column with the number so that your reviewers can still see it. (Note: In the future, Project Board will be programmed to capture this number in the Extension Activity form).

6) Do I have to report activities and clientele groups in Project Board? (FAQ for non-advisor academic positions but applies to all academics)

At minimum for ANR annual federal/organizational reporting purposes, please enter clientele group information for clientele who are external to ANR and enter Extension Activities information for activities with external clientele. All other activity types will populate the dossier export (optional for your use) but are not required for federal/organizational reporting.

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