Understanding the DHS Civil Rights Evaluation Tool

If your organization recently received federal financial assistance from the Department of Homeland Security or the Federal Emergency Management Agency, you will receive an email notifying you that you must complete a Civil Rights Evaluation Tool. The DHS Civil Rights Evaluation Tool (CRET) is a data collection and technical assistance tool to assist recipients of DHS financial assistance in understanding and meeting their existing requirements under civil rights laws and regulations.  

Recipients of federal financial assistance from DHS or one of its awarding component agencies (e.g., FEMA) must complete and submit the CRET within 30 days of receipt of the Notice of Award as required by Section B.V. of the DHS Standard Terms of Conditions of Award. Recipients of multiple awards of DHS financial assistance should only submit one completed CRET for their organization, not per award.

The DHS Civil Rights Evaluation Tool

The Civil Rights Form is only two pages in length. The first section is instructions for completing the form. The second section seeks basic contact information for you and your department. The third section details the requirements and laws that you as a grantee are required to follow.

Section four consists of eight questions. The first two ask if you have had any civil rights complaints filed against your organization. It asks whether these were employment or non - employment related. It also asks if your organization has had any civil rights reviews in the past two years and to detail information on these reviews.

Policies

The next five questions deal with requests for you to provide copies of the following documents:

1. Your department’s nondiscrimination policy
2. Your department’s complaint process. This is the procedure for someone to follow when they feel discrimination has occurred.
3. Your department’s plan to ensure that any subrecipients of your grant follow applicable civil rights regulations.
4. Your department’s policy that details equal opportunity to individuals with disabilities.
5. Your department’s policy for providing services for individuals with limited English proficiency.

Where Can I Find This Information?

Before you throw in the towel and say, "We are never applying for a grant again," keep in mind this new mandate isn’t as bad as it sounds. First, if your agency subscribes to Lexipol’s policy management solution, you should have most of these policies at your fingertips.

If you don’t have any of the policies that the DHS Civil Rights Evaluation Tool requires, there are several sources where you can probably obtain all these documents and adapt them to your department.

Most non-profit organizations that deal with federal programs have been mandated to have these policies in place for decades. So have school districts, municipal governments, institutions of higher learning, childcare centers and other similar organizations that utilize federal funds to provide their programs. You can adapt these documents to your department and (if appropriate) vote on them at your next department meeting.

Note: Use caution when adapting another organization or department’s policy to your agency. Nondiscrimination policies are not one-size-fits-all. It’s not enough to just say you’ve adopted the policy; it must be fully implemented, including the creation of procedures, designation of coordinators, member training, etc.

Here are several other resources to consider when developing the policies required by the DHS Civil Rights Evaluation Tool:

• FAQs: DHS Civil Rights Evaluation Tool
• How-to Guide on Completing Section 4 of the DHS Civil Rights Evaluation Tool
• Monthly webinars: The Office of Civil Rights and Civil Liberties (CRCL) conducts monthly webinars on recipient civil rights requirements related to the CRET. If you would like to sign up for these webinars, email CRCL at CivilRightsEvaluation@hq.dhs.gov.
• Quarterly Resource Emails: CRCL issues quarterly emails to DHS recipients that provide up-to-date information on reminders, resources, upcoming events and FAQs to assist recipients in meeting their civil rights requirements. To receive these resources, email CRCL at CivilRightsEvaluation@hq.dhs.gov.

As we receive additional information on this new requirement, we will make it available to our readers.