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West Virginia WIC Policy & Procedure 1.08 1.08 Civil Rights Effective Date: 7/19/22 E. Compliance Reviews 1. The Local Agency will be monitored on civil rights during the State Agency Local Agency Program Review and Local Agency Internal Review. See Policy 9.01 State Agency Review of Local Agency Program, Attachments 2 and 4. a. The Civil Rights Notebook will be examined to see that it contains the appropriate documents. b. The Monitor will look for appropriate use of the FNS-approved nondiscrimination statement and the posting of the And Justice For All poster. c. The Monitor will inquire about methods used to collect racial/ethnic data. d. The Monitor will ask several questions to assess if there are any operational procedures which have either deliberately or unknowingly resulted in discrimination. e. The Local Agency will address deficiencies found during the monitoring and write a plan for corrective action. F. Civil Rights Training 1. The Local Agency Civil Rights Coordinator will: a. Provide civil rights training to all new WIC personnel; b. Provide annual civil rights training to all Local Agency staff. Annual training will be due in the same calendar month each year. Training may be as a group or by individual. All persons must complete training between the first and last day of the calendar month. Training may occur earlier (less than 12 months from the last training) but will be due again no later than the same calendar month in the next year (See Policy 1.19, WIC Staff Training); and c. Use the training curriculum provided by the State Agency or obtain prior approval on other Civil Rights Training curriculum. 2. Civil rights training will include, but not limited to, the following: a. Collecting and using racial/ethnic data b. Effective public notification systems c. Complaint procedures d. Compliance Review Techniques e. Resolution of noncompliance f. Requirements for reasonable accommodation of persons with disabilities g. Requirement for language assistance h. Conflict resolution, and i. Customer Service G. Civil Rights Complaints 5 of 8