The Pennsylvania Civil Rights Compliance Questionnaire serves as a critical tool for facilities and programs across the state to ensure they are abiding by laws that prohibit discrimination. This comprehensive form requires entities to document their policies and practices related to nondiscrimination in employment and the delivery of services, catering to various groups including but not limited to race, sex, color, national origin, ancestry, religious creed, disability, and age. It prompts an introspection on the availability of policies advising against discrimination, how these policies are disseminated, and the measures taken to accommodate diverse needs, including those of individuals with limited English proficiency or disabilities.
In the Commonwealth of Pennsylvania, the Civil Rights Compliance Questionnaire serves as a crucial document for facilities and providers seeking state certification or licensing. This form is designed to ensure that entities comply with civil rights laws related to nondiscrimination in service delivery and employment practices. Entities are asked to provide detailed information including their nondiscrimination policies, measures to disseminate these policies among clients, staff, and the public, and specific strategies to accommodate and integrate minorities, persons with disabilities, and those with limited English proficiency. Additionally, the questionnaire covers the facility's efforts in advertising, the accessibility of physical spaces, and the process for handling complaints of discrimination. This comprehensive approach not only aligns with federal and state antidiscrimination laws but also promotes an inclusive and equitable environment for employees, clients, and residents. Facilities must attest to their compliance by providing thorough information on their practices, adjustments made for accessibility, and the demographic makeup of both their clientele and board members, reflecting their commitment to civil rights and equal opportunity.
CIVIL RIGHTS COMPLIANCE QUESTIONNAIRE
Certificate/Licensing Number:
NEW:_____
RENEWAL:______
Legal Entity Name
Responsible Official
Mr. ( ) Ms. ( )
Mrs. ( )
Title
Address
City
County
State
Zip Code
Phone #: (
)
Facility Name
Facility Administrator/Director
email address:
NOTE:
Type of System:
_____Multi-facility (One owner, many sites)
_____Multi-type (One owner, many services)
_____Single site (One owner, one site)
_____Other (specify)
PROGRAM:
TYPE OF
Service
Personal Care Home
Child Day Care
Child Welfare Service
(Public)
(Private)
Office of MHSAS
Office of Mental
Retardation
If additional space is required, please attach a separate 81/2 x 11 sheet to complete answers. Please denote license number on additional sheets. Be sure to number your corresponding answer.
Nondiscrimination in Employment and Services
1)Has the facility developed a nondiscrimination in service policy statement and a nondiscrimination in employment policy statement, signed by the responsible official, that advises clients/residents/parents/guardians, the public and employees that services and employment are provided in a nondiscriminatory manner, without regard to race, sex, color, national origin (address issue of Limited English Proficiency, in the service policy only), ancestry, religious creed, disability, and age?
___Yes
Provide copy (ies).
___No
2)How are the policies disseminated to clients/residents/parents/guardians, the general public and employees of the facility? Check all that apply.
___Employee/Client Orientation
___Staff Meetings/Conferences
___Language Card
___Written Announcements
___Interpreter Services
___Other (explain)
___Postings (specify locations)
___Sign Language
3) Does the facility currently serve Non-English speaking clients?
___Yes (if yes, explain method used to communicate with them)
4)If the facility advertises its services and employment opportunities to the public, does the facility include the nondiscrimination clause in brochures, media notices and/or posters?
___Yes (provide sample of AD)
___No (Explain)
1
5)Are clients, residents, parents/guardians informed that complaints of discrimination may be filed with the U.S. Department of Health and Human Services’ Office of Civil Rights, the DPW Bureau of Equal Opportunity
(BEO) and/or the Pennsylvania Human Relations Commission (PHRC)?
___Yes (Explain how the content is disseminated)
___ No (Please Explain)
6)Has information been provided to all staff regarding their rights to file complaints of employment discrimination based on Title VII of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and/or the Pennsylvania Human Relations Act of 1955, as amended with the PHRC or Equal Employment Opportunity Commission (EEOC)?
___ Yes (Please specify method used to inform staff)
____ No
___Employee orientation
___Staff meetings/conferences
___Written announcements
7)Are restrooms, drinking fountains (e.g. human needs facilities) accessible to disabled clients/ residents/ parents/ employees/ visitors?
___ Yes
____ No ( Explain).
8)How are minorities and persons with disabilities or with Limited English Proficiency integrated into programs and activities?
Please Explain
9)What methods are employed to make services accessible to those who may have mobility or sensory
impairments? CHECK ALL THAT APPLY
___Building modifications
___Program relocation within the structure
___Other (specify)
___Auxiliary aids
___Program relocation to another structure
10)Does the facility’s nondiscrimination policy state that a reasonable accommodation will be provided for employees/clients with a disability (e.g. hearing, speech, vision, mobility impairments)? Have any been
granted/denied in the past 12 months?
Please Explain.
11)Within the last 12 months, have any complaints of discrimination been filed with PHRC or EEOC? List each and explain in detail the current status.
Governing Board – If Applicable
1)What policy or criteria is used to select Board members?
2)If the facility has a Board, describe methods and materials used to orient the Board to its Civil Rights compliance requirements.
The information submitted is, to the best of my knowledge, true and we intend to be bound by it.
___________________________
_______________________________
____________
Responsible Official Name (Print)
Signature
Date
NOTE: An unannounced facility on-site review may be conducted by BEO. (Rev 10-08)
2
Attachment I
License Number__________
Facility___________________________
Language of Current Limited English Proficient Clients
Current Clients Served
Total
Black
Hispanic
White
Native
Asian/Pacific
OTHERS
American
Islander
M
F
Total Client Admissions in the Past 12 Months
Spanish
Chinese (Specify Dialects)
Russian
Cambodian
Vietnamese
Other
(Specify Language)
Board Composition – Should be reflective of community and client base –If NO Board mark N/A
Board Member
Race
Sex
Disability
Group Represented
Date Term
(Names may be omitted)
*
Expires
*Race Code: B = Black, H = Hispanic, W = White, NA = Native American, A/PI = Asian/Pacific Islander
Employment Information – Current Employees
Job Title/
Total Staff
Classification
MF
Asian/
Pacific
Others
3
For recruitment purposes: Minority/Women/Disabled Groups Contacted
Current Client Information: Please fill in the number of clients served below.
Name of Organization
Contacted
(Minority/Women/Disabled)
Purpose of
Contact
Method of
Phone/Mail
Date of Contact
Name of Person
Workforce should show parity in keeping with community/client base served.
Current Employees Enrolled in Training Programs – listing of any courses offered over the past 12 months
Course Title
Completed by MH/MR ONLY
Service Offered under
license number:
REV (10/08)
4
COMMONWEALTH OF PENNSYLVANIA (►Use Private Letterhead)
SAMPLE # 1 - CENTRAL REGION
SUBJECT: Nondiscrimination Policy Statement
Equal Employment Opportunity
TO: Staff
FROM: (►Insert Director’s Name and Signature)
An open and equitable personnel systems will be established and maintained. Personnel policies, procedures and practices will be designed to prohibit discrimination on the basis of race, color, religious creed, disability, ancestry, national origin (including limited English proficiency), age, or sex.
Employment opportunities shall be provided for applicants with disabilities and reasonable accommodation(s) shall be made to meet the physical or mental limitations of qualified applicants or employees.
Any employee who believes they have been discriminated against, may file a complaint of discrimination with any of the following.
(►Insert Provider/Facility’s Name)
(►Insert Address)
Department of Public Welfare
PA Human Relations Commission
Bureau of Equal Opportunity
Harrisburg Regional Office
Room 223, Health & Welfare Building
Riverfront Office Center
625 Forster Street
1101 S. Front St., 5th Floor
Harrisburg, PA 17120
Harrisburg, PA 17104
U.S. Dpt. of Health & Human Services
Office for Civil Rights
Suite 372, Public Ledger Bldg.
150 South Independence Mall West
Philadelphia, PA 19106-9111
5
SAMPLE # 2 – CENTRAL REGION
SUBJECT: Nondiscrimination in Services
TO: Patients/Clients/Residents/Parents
(►Insert one of the above, as applicable)
Admissions, the provisions of services, and referrals of clients shall be made without regard to race, color, religious creed, disability, ancestry, national origin (including limited English proficiency), age, or sex.
Program services shall be made accessible to eligible persons with disabilities through the most practical and economically feasible methods available. These methods include, but are not limited to, equipment redesign, the provision of aides, and the use of alternative service delivery locations. Structural modifications shall be considered only as a last resort among available methods.
Any individual/client/patient/student (and /or their guardian) who believes they have been discriminated against, may file a complaint of discrimination with:
(►Insert Provider/Facility Name)
6
SAMPLE # 1 – SOUTHEAST REIGON
110 North 8th Street
Suite 501
Philadelphia, PA 19107
Commonwealth of Pennsylvania
DPW/ Bureau of Equal Opportunity
Southeast Regional Office
801 Market Street, Suite 5034
7
SAMPLE # 2 – SOUTHEAST REGION
8
SAMPLE # 1 – WESTERN REGION
An open and equitable personnel systems will be established and maintained. Personnel policies, procedures and practices will be designed to prohibit discrimination on the basis of race, color, religious creed, disability, ancestry, national origin, age, or sex.
301 Fifth Avenue
Suite 390, Piatt Place
Pittsburgh, PA 15222
U. S. Department of Health and Human Services
Western Regional Office
Philadelphia, PA 19106
Suite 410, Piatt Place
Pittsburgh, PA 15222-1210
9
SAMPLE # 2 – WESTERN REGION
FROM:(►Insert Director’s Name and Signature)
10
When it comes to ensuring civil rights compliance, accurately filling out the required forms is crucial. The Pennsylvania Civil Rights Compliance Questionnaire is an essential document for facilities to demonstrate their adherence to nondiscrimination practices in both employment and service provision. This form helps ensure that everyone has equal access and opportunities regardless of race, color, disability, ancestry, national origin, age, or sex. The following steps will guide you through the process of completing the form accurately and thoroughly.
Remember to attach a separate 8 1/2 x 11 sheet to complete answers if additional space is required, noting the license number and corresponding answer number on the additional sheets. This careful documentation and attention to detail will contribute significantly to maintaining high standards of civil rights compliance within your facility.
What is the purpose of the PA Civil Rights Compliance Questionnaire?
The purpose of the PA Civil Rights Compliance Questionnaire is to ensure that facilities operating under various licenses in Pennsylvania, such as personal care homes and child care services, adhere to non-discrimination policies in both employment and the provision of services. It requires facilities to demonstrate their compliance with federal and state civil rights laws by documenting their policies, practices, and measures that guarantee services and employment opportunities are offered without discrimination based on race, sex, color, national origin, ancestry, religious creed, disability, and age.
Who is required to complete the PA Civil Rights Compliance Questionnaire?
Facilities in Pennsylvania seeking to obtain or renew a license for operating services such as personal care homes, child welfare services, child day care, mental health and substance abuse services, and others, must complete the PA Civil Rights Compliance Questionnaire. It is applicable to multi-facility, multi-type service providers, single site operations, as well as other service models as specified in the form.
How should the policy statements on non-discrimination be disseminated according to the form?
According to the PA Civil Rights Compliance Questionnaire, the developed non-discrimination policy statements must be disseminated in a variety of ways to ensure that clients, residents, parents/guardians, the general public, and employees are aware of them. The form suggests dissemination methods such as during employee/client orientation, staff meetings/conferences, through written announcements, interpreter services, postings at specific locations within the facility, and the use of sign language among others.
What happens if a complaint of discrimination is filed?
Facilities are required to inform clients, residents, parents, and guardians that complaints of discrimination based on the denial of services or employment opportunities can be filed with the U.S. Department of Health and Human Services’ Office of Civil Rights, the Department of Public Welfare (DPW) Bureau of Equal Opportunity (BEO), or the Pennsylvania Human Relations Commission (PHRC). The form asks facilities to explain how this information is disseminated. Facilities must also report any discrimination complaints filed with these agencies in the past 12 months, including the current status of each complaint.
How are facilities expected to integrate minorities and persons with disabilities or with Limited English Proficiency?
Facilities are required to explain their methods and approaches to ensure full integration of minorities and persons with disabilities or those with Limited English Proficiency into their programs and activities. This could involve building modifications for accessibility, program relocation, provision of auxiliary aids, or other techniques ensuring that all individuals have equal access to the services offered, regardless of their physical abilities or language proficiency.
Not providing a clear distinction between new and renewal applications. Applicants often overlook the check boxes indicating whether they are applying for a new certificate/license or renewing an existing one.
Failing to correctly identify the legal entity name and responsible official. This oversight can lead to confusion regarding the accountable party for compliance.
Omitting the title or incorrectly filling the contact information of the responsible official and facility administrator/director. Accurate details are essential for follow-up and verification processes.
Incorrectly describing the type of system operated by the entity. This information is crucial for understanding the scope of services and compliance requirements.
Overlooking the need to attach additional sheets for explanations that don't fit in the provided space. When additional information is necessary, failing to attach extra sheets can result in incomplete submissions.
Neglecting to indicate the development and dissemination of nondiscrimination policies. The form requires confirmation that these policies have been established and how they're communicated to employees and clients.
Forgetting to specify how the facility caters to non-English speaking clients or those with disabilities. Providing details on communication methods and accessibility measures is essential for compliance.
Omitting examples or proof of advertisements that include the nondiscrimination clause. This evidence supports the facility’s commitment to inclusive practices.
Failing to detail the distribution of information regarding the right to file discrimination complaints. This information is vital to ensure transparency and accessibility of complaint procedures.
Incorrectly reporting or not reporting on the accessibility of facilities to clients and employees with disabilities. Information on restrooms, drinking fountains, and service accessibility is required for compliance.
The Pennsylvania Civil Rights Compliance form is a crucial document that ensures organizations and businesses comply with civil rights laws ensuring nondiscrimination in employment and services. Alongside this form, several other documents and forms often play a pivotal role in strengthening an organization's compliance framework. These documents not only support the information provided in the civil rights compliance form but also help organizations in demonstrating their commitment to civil rights and nondiscrimination.
Together, these documents form a comprehensive approach to ensuring compliance with civil rights legislation, providing a framework for accountability and transparency. Each document serves as a building block in creating an inclusive environment where discrimination is not tolerated. Organizations are encouraged to regularly review and update these documents to reflect current laws, regulations, and best practices in civil rights compliance.
The Pa Civil Rights Compliance form is structured to meet multiple standards and requirements similar to other important documents in the field of civil rights and compliance. This form, focusing on ensuring non-discrimination in both employment and the provision of services, has counterparts in various sectors. Below are details about similar documents and how they relate or differ.
One comparable document is the Equal Employment Opportunity (EEO) Compliance Form. Like the Pa Civil Rights Compliance form, EEO forms are used by organizations to affirm their commitment to preventing workplace discrimination based on race, color, religion, sex, national origin, age, disability, or genetic information. These forms typically require an organization to provide data about their workforce demographics and to describe their policies and practices designed to ensure equal employment opportunities for all. Both documents serve as a tool for organizations to evaluate and report on their non-discrimination practices, although EEO forms are more specifically targeted towards employment practices rather than the broader scope of services included in the Pa Civil Rights Compliance form.
Another document with similarities is the Section 504 Self-Evaluation Form. Section 504 of the Rehabilitation Act of 1973 prohibits discrimination based on disability in any program or activity receiving Federal financial assistance. The self-evaluation form requires entities to review their policies and practices to ensure they are not discriminatory towards individuals with disabilities and to make adjustments as needed. The Pa Civil Rights Compliance form also includes considerations for individuals with disabilities but combines these concerns with broader non-discrimination clauses. Both documents are essential for organizations to internally audit their compliance with civil rights laws, albeit with Section 504 having a focused lens on disability.
Lastly, the form shares common goals with the Office for Civil Rights (OCR) Compliance Certification. This certification is required for healthcare providers and organizations to attest their compliance with federal civil rights laws, HIPAA, and the Patient Safety and Quality Improvement Act. While the OCR Compliance Certification is more specific to the health care industry, it similarly mandates organizations to implement non-discrimination and accessibility policies. The Pa Civil Rights Compliance form and the OCR Certification both necessitate organizations to document and affirm their commitment to civil rights, yet the specific focus and regulatory framework they operate within differ significantly.
In essence, the Pa Civil Rights Compliance form is part of a broader ecosystem of documents and forms designed to promote and ensure equality and non-discrimination across various facets of society. Although each document has its specific focus—be it employment, disability rights, or healthcare—they all underscore the fundamental importance of compliance with civil rights laws and regulations.
When completing the Pennsylvania Civil Rights Compliance Questionnaire, it is important to follow these guidelines to ensure that your submission is accurate, comprehensive, and compliant with state regulations:
Adhering to these dos and don'ts helps demonstrate your facility's commitment to civil rights compliance and ensures a thorough and thoughtful completion of the Pennsylvania Civil Rights Compliance Questionnaire.
When it comes to compliance with civil rights in Pennsylvania, there are several misconceptions surrounding the Civil Rights Compliance (CRC) form. Understanding these misconceptions can empowers organizations to fulfill their obligations more effectively and uphold the highest standards of equality and non-discrimination.
There is a belief that the Civil Rights Compliance form is only necessary when applying for a new license or certification with the state of Pennsylvania. However, this form is equally important during the renewal process. It ensures that facilities continue to meet civil rights compliance requirements over time, not just at the point of initial application.
While filling out and submitting the CRC form is crucial, compliance does not stop there. Facilities must actively implement the policies they outline in the form, including nondiscrimination in service policies and employment practices. Regular training, policy dissemination, and adjustments based on feedback and changing laws are all part of ongoing compliance efforts.
It's a common misunderstanding that the form focuses exclusively on preventing discrimination based on race and gender. In reality, the CRC form covers a broad range of nondiscrimination criteria, including, but not limited to, national origin, ancestry, religious creed, disability, and age. Facilities need to ensure their services and employment practices are non-discriminatory across all these dimensions.
Another misconception is that the absence of formal complaints equates to full compliance. However, compliance is not only about managing and preventing complaints but also about proactive measures to ensure nondiscrimination. This includes making services accessible to non-English speakers, ensuring facility accessibility, and integrating minorities and persons with disabilities into programs and activities. Compliance is an active, ongoing process requiring constant attention and improvement.
Navigating the nuances of the Civil Rights Compliance form and its requirements is essential for all facilities and organizations subject to its mandates. By addressing these misconceptions, facilities can better understand their obligations and promote an environment of equality and inclusivity.
Filling out the Pennsylvania Civil Rights Compliance form is a critical step for facilities to ensure they adhere to legal standards regarding nondiscrimination. Here are six key takeaways to guide you through the process and ensure compliance:
Ultimately, the Pennsylvania Civil Rights Compliance form serves as a comprehensive tool to ensure facilities operate in a non-discriminatory manner, respecting and upholding the civil rights of their clients, residents, and employees. Through diligent completion and adherence to its requirements, facilities can create inclusive environments that honor the rights and dignity of every individual they serve or employ.
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