Understanding Title VI
Understanding Title VI of the Civil Rights Act of 1964
What is Title VI?
This statute of the Civil Rights Act of 1964 provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity receiving Federal financial assistance.
Why Title VI is important?
Federally assisted programs administered by Federal government agencies impact all aspects of life. This assistance by way of a grant, loan or contract, creates a legal obligation for the recipients, sub-recipients and contractors to ensure that all persons are afforded an equal opportunity to benefit and participate regardless of their race, color, or national origin. It applies to all programs, services and activities, that are funded, sponsored or supported by the Federal government.
Title VI Definitions
Federal Assistance: Includes grants and loans of Federal funds; the grant, donation of Federal property and interests in property; the detail of Federal personnel; the sale or lease of, and the permission to use, Federal property or any interest in such property without consideration or at a nominal consideration, or at a consideration which is reduced for the purpose of assisting the recipient, or in recognition of the public interest to be served by such sale or lease to the recipient; and any Federal agreement, arrangement, or other contract which has, as one of its purposes, the provision of assistance.
Persons: Where designation of persons by race, color, or national origin is required, the following designations ordinarily may be used: "White not of Hispanic origin", "Black not of Hispanic origin","Hispanic", "Asian or Pacific Islander", "American Indian or Alaskan Native". Additional subcategories based on national origin or primary language spoken may be used, where appropriate, on either a national or a regional basis.
Beneficiary: Any person or group of persons (other than States) entitled to receive benefits, directly or indirectly, from any Federally assisted program (ie. relocates, impacted citizens, communities, etc.)
Discrimination: The act (or action) whether intentional or unintentional, through which a person in the United States, solely because of race, color, or national origin has been otherwise subjected to unequal treatment under any program, service or activity receiving Federal financial assistance.
Specific Prohibited Discriminatory Actions:
1. A recipient under any program may not on the grounds of race, color, or national origin: a) deny a person any service, financial aid, or other benefit; b) provide any service, financial aid, or other benefit to a person which is different, or is provided in a different manner, from that provided to others; c) subject a person to segregation or separate treatment in any matter; d) restrict a person in any way in the enjoyment of any advantage or privilege enjoyed by others; e) treat a person differently from others in determining whether he or she satisfies any admission, enrollment, quota, eligibility, membership, or other requirement or condition which persons must meet in order to be provided any service, financial aid, or other benefit; f) deny a person an opportunity to participate in the program through the provision of services or otherwise afford him an opportunity to do so which is different from that afforded to others; g) deny a person the opportunity to participate as a member of a planning, advisory, or similar body which is an integral part of the program.
2. Use criteria or methods of administration while determining the types of services, financial aid, or other benefits, that could have the effect of subjecting persons to discrimination because of their race, color, or national origin, or have the effect of defeating or substantially impairing accomplishment of the objectives of the program with respect to individuals of a particular race, color, or national origin.
3. In determining the project site or location of facilities, a recipient may not make selections with the purpose or effect of excluding persons from, denying them the benefits of, or subjecting them to discrimination on the grounds of race, color, or national origin.
Title VI and Non-Discrimination Notice of Rights of Beneficiaries
The Central Massachusetts Metropolitan Planning Organization (CMMPO) hereby state their policies to uphold and assure full compliance with Title VI of the Civil Rights Act of 1964, the Civil Rights Restoration Act of 1987, and related federal and state statutes and regulations.
Title VI prohibits discrimination in federally assisted programs and requires that no person in the United States of America shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity receiving federal assistance.
CMMPO Obligations and Responsibilities
1. Develop a Title VI Program or annual implementation plan
2. Display and disseminate Title VI and civil rights information in accessible formats and languages other than English
3. Collect and analyze demographic data
4. Monitor and review program areas to determine the effectiveness and compliance
5. Staff training and continued capacity building sessions
6. Explain the procedures for filing and handling a Title VI complaint
7. Log, track, and investigate and follow-up any Title VI complaint received
8. Provide engagement opportunities and outreach activities to minority and low income population, including persons with limited English proficiency
9. Provide Title VI assurances
10. Identify mitigation measures for minorities and low income population