Civil Rights

C.E.S.P. 2-2: All Reasonable Efforts

Date Revised: 7-24-2014
Supersedes: 1 style="font-size: 12px; line-height: 1.333em;">1-16-2007

Summary: Establishes policy relating to "all reasonable efforts" to achieve balanced participation in all Extension programs, including membership in E.H. Clubs and 4 – H Clubs.

"All reasonable efforts" consist of a series of approaches that are required of Extension staff to solicit participation of the underrepresented group in an Extension programs.  These are documented efforts to target and solicit the particular underrepresented group that is not participating in the program.  These are also known as affirmative action steps and are required when programs do not meet balanced participation requirements.  A sincere effort must be made to encourage participation by minorities or the underrepresented.  It is not enough to simply announce the program is open to all.  Below are some of the situations that would require "all reasonable efforts" by Extension staff:   

• an Extension sponsored group that does not have a balanced membership and is in a mixed racial/ethnic membership area;
• advisory groups that do not reflect the composition of the potential audience; and/or
• program participation in which certain groups are consistently underrepresented.

When these types of situations exist, Extension personnel must take responsibility for implementing the steps below to attain the goal of balanced participation.  These steps must be repeated and documented until the goal of balanced participation is met and maintained.  Steps include:

• Use of media outlets that target the underrepresented group to announce programs and events, i.e. radio stations, newspapers and television.  Because media outlets may eliminate the non-discrimination statements due to space limitations, it is important to include in your civil rights file the original copy that was sent to media attached to the copy that was actually printed.
• Development diverse flyers, brochures, posters, announcements to be placed in locations frequented by the underrepresented group;
• Write personal letters to and make personal contact with members of the underrepresented group to encourage participation;
• Make personal contact with leaders from the underrepresented group to seek their assistance in reaching this audience;
• Seek assistance from other community groups to encourage participation.

Grassroots Organizations

Grassroots organizations should be utilized in outreach efforts to solicit participation of underrepresented groups.  These organizations are usually created at the local level with many volunteers supporting their political, social, and/or economic missions.  Each county should have on file a list of all grassroots organizations in the county.  Examples of grassroots organizations include:  National Association for the Advancement of Colored People (NAACP),   Minority Health Coalitions, Better Community Developers, Faith-Based Organizations, Arkansas Community Organizations, local food bank organizations; minority churches; women groups; local coalitions; civic, fraternal and social organizations whose membership reflects diversity; and local literary councils.

4-H and Extension Homemakers Clubs

If a 4-H or Extension Homemakers Club meets or is located in an interracial membership area, then the membership of the club should be reflective of the membership area.  "Membership area” is defined as the specific area served by the club from which it might reasonably be expected to draw members.  To be in compliance, a club must have a "balanced membership.”  Balanced membership is achieved when the number of members of the underrepresented race and/or ethnicity reaches 75% of the number of the non-majority members the club would have if its racial composition were exactly proportional to that of the membership area.  For example, a club with 20 members in a membership area where blacks comprise 20 percent of the population would be exactly proportional (in parity) if it had 4 black members. This club would be considered to have "balanced membership," however, if it had 3 black members (75 percent of the ideal goal).

If a 4-H or Extension Homemakers Club does not have a balanced membership, then "all reasonable efforts", Extension personnel must take the steps outlined above.

Location of all 4-H and Extension Homemakers Clubs must be identified on a county map and maintained in the county civil rights file.

Documentation

 "all reasonable efforts" must be documented by Extension personnel.  When outreach efforts to the underrepresented group are not documented, the burden of proving nondiscrimination is on the agency or organization.  Each county office’s should have an "all reasonable efforts" folder which contains the following outreach efforts:

• Flyers, press releases, personal letters, invitation letters and other outreach correspondence and program brochures sent to targeted individuals and organizations (including grassroots organizations) with notations of where and when; regular  4-H and/or Extension Homemaker club meeting are held and who to contact for more information about individual clubs.
• Notes about all special targeted efforts to reach people from underrepresented groups; and
• Notes from meetings and phone conversations that demonstrate outreach to people from underrepresented groups.

Examples of memos and documentation that would satisfy civil rights documentation requirements:

✓ "Telephone contacts were made with these potential Hispanic participants…"

✓ "Went to African American church, AME Episcopal Church, and shared information about our parenting program, passed out brochures ...”

✓ "Public announcement about EHC clubs made on 106.7 minority radio station…”

✓ "Personally invited 10 Asian seniors to Master Garden Open House and discussed the programs with them.”