19-04 Title VI Program Plan

Introduction

• The Kansas City, Missouri Police Department has a Title VI Program Plan to ensure compliance with civil rights laws and other nondiscrimination authorities.
• The plan prohibits discrimination based on race, color, national origin, limited English proficiency, sex, sexual orientation, gender identity, age, religion, disability, or low-income level.

Key Definitions

• Assurances: A Board-approved document that gives notice to federal and state authorities that the Department abides by all nondiscrimination laws.
• Civil Rights Laws: Laws that apply to Federal financial assistance compliance, including Title VI of the Civil Rights Act of 1964, Title V of the Rehabilitation Act of 1973, Title IX of the Education Amendments of 1972, and the Age Discrimination Act of 1975.
• Disability: A physical or mental impairment that substantially limits one or more of the major life activities of an individual, or being regarded as having such an impairment.
• Federal Financial Assistance: Includes grant funds, equipment, Federal training, donated real or personal property, etc.
• Gender Identity: A person's actual or perceived gender-related identity, appearance, or behavior, which may be different from what is traditionally associated with their physiology or assigned gender at birth.
• Low-Income Level: A person whose household income is at or below the U.S. Department of Health and Human Services poverty guidelines.
• Nondiscrimination Authorities: Federal financial assistance rules that may require compliance with the Title I of the Omnibus Crime Control and Safe Streets Act of 1968, Victims of Crime Act of 1984, or Violence Against Women Act of 1994.
• Program or Activity: All of the operations of the Department as provided under law.
• Title VI: A section of the Civil Rights Act of 1964 that prohibits discrimination by recipients of Federal financial assistance on the basis of race, color, and national origin, including the denial of meaningful access for limited English proficient (LEP) persons.
• Title VI/ADA Coordinator: The individual responsible for the oversight, coordination, and monitoring of all initiatives appearing in this written directive.
• Title VI Program: A collection of documents, processes, procedures, and notices developed by the Department to demonstrate how it is complying with the applicable Federal or state agency's requirements for implementation of a Title VI program.

Policy

• Department members will ensure that no person is excluded from participation in, denied the benefits of, or subjected to discrimination under any Kansas City Missouri Board of Police Commissioners program or activity.
• All members will be trained to understand and meet Title VI requirements in the performance of their duties.
• Title VI information will be displayed in all Department facilities to which the public has access and on the Department's external website.

Procedures

• Title VI Resources: The following materials and resources are available for members' use when responding to questions or concerns from the public regarding Title VI:
  • Public Notice of Title VI Program Rights, Form 5115 P.D. (poster form)
  • Community Complaint Report, Form 337 P.D. ( downloadable from the I:Drive Word Templates folder or accessed on the Office of Community Complaints (OCC) website)
  • Title VI Program Plan Questionnaire, Form 5114 P.D. (to be completed by the complainant after an individual files a Title VI complaint)
  • Title VI Webpage (on the Department website, containing general Title VI information, Public Notice of Title VI Program Rights, Form 5115 P.D., Department forms and directives, and additional Title VI resource links)
  • Statistical Data (maintained by the OCC Director for the collection of statistical data)
• Grant Applications Requiring Title VI Assurances:
  • When applying for a grant that requires Title VI Assurances, members will contact Fiscal Division personnel and request a copy of the Title VI Assurance document(s).
  • The Fiscal Division will notify the Coordinator of new grant application requests.
• Coordinator Responsibilities:
  • Review Title VI and other nondiscriminatory authority complaints and recommend a best course of action regarding any potential investigation.
  • Coordinate community outreach efforts.
  • Coordinate with OCC to maintain data on Title VI complaints filed with the Department.
  • Create and maintain a Title VI program to meet the continued needs of the Department and compliance with Federal grants.
  • Ensure Department-wide compliance with Title VI requirements, including annual review of the Title VI Program.
  • Be responsible for coordination of, and compliance with, all initiatives appearing in this written directive.

Complaint Procedures

• Filing a Title VI Complaint:
  • Members will accept citizen complaints in accordance with the written directive entitled, "Response to Community Complaints."
  • The Community Complaint Report, Form 337 P.D., may be downloaded from the I:Drive Word Templates folder or accessed on the OCC website.
  • Members will assist complainants in preparing written forms, if necessary.
• Complaint Process:
  • Upon receipt of a Title VI complaint from OCC, the Coordinator will send the complainant an acknowledgement letter informing them of the receipt of the complaint and whether the complaint has been accepted for further investigation or denied.
  • If accepted, the Title VI Program Plan Questionnaire, Form 5114 P.D., will be included with the letter.
  • The Coordinator or designee will investigate the complaint and prepare an investigative report.
  • The Coordinator will make the final determination on the disposition of the complaint and issue one of two letters to the complainant: a closure letter or a letter of finding.

Annexes

• Annex A: Title VI Program Complaint Investigation Procedures:
  • Filing a Title VI Complaint
  • Complaint Process
• Annex B: Outreach, Resource, and Data Collection:
  • Outreach Activities
  • Resource Activities
  • Data Collection and Reporting### Coordinator's Role
• Collects statistical data on participants and beneficiaries of subrecipient's programs to ensure non-discrimination.
• Generates annual reports and other reports as needed to assess the Department's efforts in providing meaningful access to services and programs.

Report Contents

• Reviews and analyzes community outreach efforts, capital and human resources dedicated to Title VI services, demographic data, Title VI and LEP training, and recommendations for changes to applicable written directives.

Report Submission

• The report is submitted to the Chief of Police.

Program Management

• The Fiscal Division prepares and maintains a current list of Federal financial assistance received by the Department, including:
  • Type of Federal financial assistance
  • Associated Federal agency
  • Pass-through agency
  • Name of grant
  • External or internal reference number
  • Whether it is a pass-through
  • Whether Title VI is included in assurances
  • Start date of Federal financial assistance
  • Anticipated end date

Compliance with Federal Requirements

• The Coordinator and Fiscal Division have access to the current Federal financial assistance list.
• The Coordinator, with the Fiscal Division's assistance, identifies specific Federal agencies with additional Title VI requirements.
• Personnel responsible for contracts, bids, and other agreements ensure compliance with Federal grant requirements.
• Questions regarding specific language inclusion are directed to OGC.

This quiz covers the Kansas City, MO. Police Department's procedural instruction on Title VI, including the policy statement and codes of ethics.