Grant Subrecipient – EEO Compliance Requirements
To be EEO compliant, Subrecipients must provide the following to your program specialist.
U.S. Department of Justice (DOJ), Office of Civil Rights – Online Certification Form
Subrecipients submit a Certification Form online to the Office for Civil Rights (OCR). This form:
- Confirms the obligation to develop and submit an EEOP Utilization Report to the OCR; or
- Declares an exemption from the EEOP Utilization Report submission if applicable.
U.S. Department of Justice (DOJ), Office of Civil Rights – EEOP Utilization Report
Subrecipients develop and submit an EEOP Utilization Report if applicable to the Office of Justice Programs (OJP).
- Develop (No submittal) EEOP Utilization Report
- The subrecipient is a state or local government agency or a business; AND
- The subrecipient has 50 or more employees; AND
- The subrecipient has received a single award of $25,000 or more
- Develop and Submit EEOP Utilization Report
Subrecipients who meet the above criteria AND receive a single award of $500,000 or more. OCR sends a federal letter of approval good for 24 months from the date of the letter.
- Exempt from EEOP Utilization Report
Subrecipients who meet the following criteria are exempt from developing and submitting an EEOP:
- The subrecipient is a nonprofit, Indian Tribe, Medical or Educational Institution; OR
- The subrecipient is a state or local government or private entity with less than 50 employees; OR
- The subrecipient is a state or local government or private entity that receives less than $25,000.
- Non Discrimination Policy
Subrecipients must have a current Equal Employment Opportunity (EEO) policy with the following:
- Direct program participants how to file a complaint.
- Show they do not discriminate in employment practices or in delivery of services.
- Disclose any adverse findings of discrimination against the Subrecipient.
- Limited English Proficiency (LEP) Process
- Provide access to services and activities, to persons with limited English. For example, written language/oral interpretation services, bilingual staff, telephone interpreters, etc.…)
- Ensure staff reviews training provided online by the U.S. Department of Justice.
- Faith-Based/Religious Organizations
- Show how religious activities are separate from grant funded services and benefits.
- Ensure participation in religious activities is voluntary.
- Find similar services for those who object to your “Religious Character”.
- Violence Against Women ACT (VAWA)/Office For Violence Against Women (OVW)
- Acknowledge that services are for all victims, regardless of sex/gender.
- Acknowledge if services received based on sex/gender.
Department of Homeland Security – Federal Funding
To receive Federal funding, the subrecipient must follow laws prohibiting discrimination. These include:
- Title VI of the Civil Rights Act of 1964. This prohibits discrimination based on race, color, or national origin (including limited English).
- Section 504 of the Rehabilitation Act of 1973. This prohibits discrimination based on disability.
- Title IX of the Education Amendments Act of 1972. This prohibits discrimination based on sex in education programs or activities.
- Age Discrimination Act of 1975. This prohibits discrimination based on age.
- U.S. Department of Homeland Security regulation 6 C.F.R. Part 19. This prohibits discrimination based on religion in social service programs.