Title VI

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Title VI of the 1964 Civil Rights Act says,”No person in the United States shall, on the grounds of race, color or national origin, be excluded from participation in, be denied the benefit of, or be subjected to discrimination under any program or activity receiving federal financial assistance.” 42 U.S.C.§2000d Title VI covers all forms of federal aid except those federally funded contracts of insurance and guaranty. It does not cover employment, except where employment practices result in discrimination against program beneficiaries or where the purpose of federal assistance is to provide employment. Nor does it apply to discrimination based on age, sex, geographical locale or wealth.

Federal financial assistance means more than just money. It is also aid that enhances the ability to improve or expand allocation of a recipient’s own resources. Examples in the City of Franklin might include:

Training of employees (permits better use of the employer)
Grants and Loans, tax-exempt bonds
Property
Loan of Personnel
Tax incentives and tax-exempt status
Technical assistance, etc.

Title VI prohibits entities from denying an individual any service, financial aid, or other benefit because of race, color or national origin. It prohibits entities from providing a different service or benefit, or providing these in a different manner from those provided to others under the program.

Title VI prohibits segregation or separate treatment in any manner related to receiving program services or benefits. It prohibits entities from requiring different standards or conditions as prerequisites for serving individuals. Title VI encourages the participation of minorities as members of planning or advisory bodies for programs receiving federal funds. It prohibits discriminatory activity in a facility built in whole or part with Federal funds. It requires information and services to be provided in languages other than English when significant numbers of beneficiaries are of limited English speaking ability. Title VI requires entities to notify the respective population about applicable programs. It prohibits locating facilities in any way that would limit or impede access to a Federally funded service or benefit. And finally, Title VI requires assurance of nondiscrimination in purchasing of services.

Title VI does not apply to Federal assistance provided through insurance or guaranty contracts, (e.g. FHA loan insurance). It does not apply to employment, except where employment practices results in discrimination against program beneficiaries or where the purpose of the Federal assistance is to provide employment. Title VI does not provide relief for discrimination based on age, sex, geographical locale, or wealth. It does not apply to direct benefit programs such as Social Security. And finally, Title VI does not apply only to contracts and set-aside programs.

There are many forms of illegal discrimination based on race, color or national origin that can limit the opportunity of minorities to gain equal access to services and programs. Among other things, in operating a federally assisted program, a recipient cannot, on the basis of race, color or national origin, either directly or through contractual means: 

Deny program services, aids or benefits.
Provide a different service, aid, or benefit, or provide them in a manner different than they are provided to others.
Segregate or separately treat individuals in any matter related to the receipt of any service, aid, or benefit.

To ensure the broad, institution wide application of Title VI and other civil rights statutes Congress passed The Civil Rights Restoration Act of 1987. This act clarifies the definition of “programs and activities” covered by the nondiscrimination provisions of civil rights statutes. The revised definition states that discrimination is prohibited throughout an entire agency or institution, if any part of that agency or institution receives Federal financial assistance. Title VI applies to discrimination throughout an agency, not just to actions involving the federally assisted program. Therefore, if an agency receives any federal financial assistance for any program or activity the entire agency is required to comply with Title VI, not just that particular program. Example: If the Police Department Operations Division receives a federal grant to purchase laptop computers to put in Police cars, all divisions of the Police Department must be in compliance with Title VI rules and regulations.

Sara E. Sylvis
Title VI Coordinator
615-791-3277
sara.sylvis@franklintn.gov

Laura Johnson
Employee Relations Specialist
615-791-3216
laura.johnson@franklintn.gov

City of Franklin Title VI Management Plan

Title VI Complaint Form

Limited English Proficiency Policy

Limited English Proficiency Law Enforcement Policy