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Civil Rights Pre-Award Compliance

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OKLAHOMA DEPARTMENT OF HUMAN SERVICES
Child Nutrition Programs
Civil Rights Pre-Award Compliance

Submit the information below prior to the receipt of federal funds:

Indicate the number of students enrolled from each racial/ethnic group for the program service area. Data may be obtained from a public school in your area or U.S. census data.

Estimated racial/ethnic data

Using the table below, indicate:

  • the number of students enrolled from each racial group;
  • the percentage of each race within the school's service area. School food authorities (SFAs) may use the data from the U.S. Census Bureau; State and County QuickFacts to determine the percentage using the Web site: http://quickfacts.census.gov/qfd/states/; and
  • enter the number of students enrolled according to ethnic group, Hispanic or non-Hispanic.
Racial and ethnic classifications - See definitions on page 2 Enrollment Program service area percentage
Ethnicity:
Hispanic or Latino
Not Hispanic or Latino
Race:
American Indian or Alaska Native
Asian
Black or African American
Native Hawaiian or other Pacific Islander
White
Other
Total students

Are there membership requirements as a prerequisite for admission?

If yes, please describe:

List names of other federal agencies which provide assistance to your organization.

Has your organization ever been found to be in Civil Rights noncompliance with any of the federal agencies who provide assistance to your organization?

If yes, explain:

Schools and/or SFAs that are not currently participating in Child Nutrition Programs but wish to apply for a program are required to submit the following items used to publicize the program's availability and nondiscrimination requirements:

  • free and reduced-price policy statements;
  • letter to parents providing notification of participation in Child Nutrition Programs;
  • public release; and
  • other materials used to publicize the program's availability and nondiscrimination requirements.

Definition of racial and ethnic classifications

American Indian or Alaska Native - a person having origins in any of the original peoples of North and South America (including Central American), and who maintains tribal affiliations or community attachment.

Asian - A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.

Black or African American - A person having origins in any of the black racial groups of Africa. Terms such as “Haitian” or “Negro” can be used in addition to “Black” or “African American.”

Hispanic or Latino - A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race. The term “Spanish origin” can be used in addition to “Hispanic” or “Latino.”

Native Hawaiian or Other Pacific Islander - A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.

White - A person having origins in any of the original peoples of Europe, the Middle East, or North Africa.

Page 2 of 2
Revised 12-1-2008
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What the Civil Rights Pre-Award Compliance Statement Is

A Civil Rights Pre-Award Compliance statement documents an applicant’s commitments and procedures for meeting nondiscrimination, equal opportunity, and accessibility requirements before a federal or state award is issued. It typically lists the laws and regulations that apply (for example, Title VI, ADA, Section 504), describes outreach and equitable procurement practices, and identifies responsible compliance personnel. Agencies use the statement to assess whether an applicant has policies, training, and recordkeeping to prevent discrimination and to ensure that federal funds will be administered consistent with civil rights obligations during the award period.

Why a Pre-Award Civil Rights Statement Matters

A clear pre-award compliance statement reduces administrative delay, demonstrates legal readiness, and helps agencies confirm eligibility for funding while protecting applicants from post-award corrective actions and sanctions.

Why a Pre-Award Civil Rights Statement Matters

Who Prepares and Reviews This Document

Preparing the statement ahead of submission improves review outcomes and reduces the chance of conditional awards or required corrective action plans.

  • Grant managers and compliance officers in government or nonprofit organizations responsible for funding proposals and conditions for federal/state awards.
  • Procurement teams and contracting officers who must confirm equitable bidding, minority- or women-owned business outreach, and nondiscrimination practices.
  • Legal and human-resources staff who maintain policy documents, training records, and complaint-handling procedures to meet award conditions.

How to Complete a Civil Rights Pre-Award Compliance Statement

Follow these core steps to prepare a complete and review-ready statement before submission to the awarding agency.

  • 01
    Gather Policies: Collect nondiscrimination, ADA, and equal opportunity policies.
  • 02
    Assign Owner: Identify the person responsible for compliance oversight.
  • 03
    Document Practices: Summarize outreach, training, and complaint procedures.
  • 04
    Attach Records: Include recent training logs, EEO reports, and monitoring plans.

Core Sections to Include in a Professional Statement

A complete pre-award compliance statement organizes obligations, practices, and evidence to show how the applicant will meet civil rights conditions if awarded funds.

Nondiscrimination Policy

State the organization’s official nondiscrimination policy, scope of coverage, and how it applies to beneficiaries and contractors during the award.

Accessibility & ADA

Describe physical and programmatic accessibility measures, reasonable accommodation procedures, and compliance with the Americans with Disabilities Act.

Title VI Protections

Explain steps to prevent race, color, or national-origin discrimination and methods for language access and outreach to limited English proficiency populations.

EEO & Workforce Practices

Summarize EEO hiring practices, affirmative outreach, and any state or local workforce goals tied to the award.

Monitoring & Reporting

Provide the monitoring schedule, performance measures, and how findings and data will be reported to the awarding agency.

Complaint Handling

Detail intake channels, investigatory steps, remedies, and how complainants will be informed of rights and timelines.

Essential Compliance and Security Declarations

Encryption: TLS 1.2/1.3 in transit; AES-256 at rest
Audit Trails: Tamper-evident logs and timestamps
HIPAA Capability: BAA available for protected health data
Regulatory Support: ESIGN and UETA compliant
21 CFR Part 11: Controls for FDA-regulated records
Certifications: SOC 2 Type II and ISO 27001

Common Pitfalls to Avoid When Preparing the Statement

  • Providing generic policy text without evidence of implementation, such as dated training records or recent monitoring results, invites follow-up questions and may delay award decisions.
  • Omitting a named compliance officer or contact creates routing issues for agency inquiries and can lead to conditional award terms requiring corrective assignments.
  • Failing to specify the exact statutes and regulations that apply to the award can cause reviewers to request clarifying amendments or additional assurances.
  • Neglecting to include language-access plans or ADA accommodation steps for program beneficiaries often triggers supplemental requirements before funds are released.

Consequences of Inaccurate or Incomplete Statements

Award Delay: Agency may postpone funding
Conditional Award: Corrective actions required
Repayment Risk: Funds may be recouped
Legal Liability: Discrimination claims increase exposure
Sanctions: Debarment or program suspension
Reputational Harm: Public disclosure of violations

How to Configure an Online Compliance Workflow

Map the digital workflow to organizational roles and evidence requirements to reduce manual steps and ensure all reviewers see the same information.

Field | Setting Data field name | Recommended configuration
Document Owner Compliance Officer | Single approver
Attachments Allow PDF uploads | Require certificate names
Reviewer Order Sequential routing | Compliance then legal
Retention Tag Apply retention policy | 7-year default

Typical Submission and Review Flow

A standard e-submission flow reduces back-and-forth by routing documents to the right reviewers in order and capturing evidence at each step.

  • Upload: Applicant uploads statement and attachments.
  • Pre-Screen: Automated checks for required fields.
  • Agency Review: Compliance officer examines substantive items.
  • Decision: Approve, request clarification, or condition award.

Digital Delivery and Platform Considerations

Choose e-submission tools that support secure attachments, robust audit trails, and role-based routing to satisfy agency review requirements.

  • Integrations: Salesforce, NetSuite, Microsoft 365
  • File Formats: PDF, DOCX, or secure HTML
  • Authentication: Email, SMS, or advanced KBA

Typical Timing and Deadlines to Watch

Agencies set specific windows for pre-award submission and may allow a short correction period; missing deadlines can remove applications from consideration.

Application Submission:

Follow the agency’s posted grant deadline precisely.

Pre-Award Review Period:

Agencies often take 30–90 days to complete compliance review.

Clarification Window:

Some agencies allow 7–30 days to supply missing items.

Conditional Remedy Deadline:

Corrective actions typically due within 30–60 days.

Record Retention Start:

Retention period begins on award execution date.

Key Milestones from Submission to Award

Track these sequential milestones during the pre-award compliance lifecycle to monitor progress and plan resources.

01

Submission Received

Agency acknowledges receipt and issues tracking number.

02

Initial Screening

Automated checks for completeness and required documents.

03

Substantive Review

Compliance specialist evaluates nondiscrimination and accessibility items.

04

Final Determination

Agency approves, conditions, or denies award based on findings.

Representative eSignature Pricing and Capabilities

Basic pricing and capability differences can affect cost and compliance. The table compares starting price, trial availability, bulk send, audit trail, and HIPAA support for common vendors.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial No No Yes, limited Yes, limited
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No

Frequently Asked Questions About Civil Rights Pre-Award Compliance

Answers to common questions about preparing, submitting, and maintaining a pre-award civil rights statement.


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