The Tennessee Arts Commission and Title VI Compliance
The Tennessee Arts Commission is a state agency that receives federal and state funding to support art organizations, activities, and artists throughout the State. The Commission seeks to cultivate the arts for the benefit of all Tennesseans and their communities and Title VI is an important part of ensuring this success.
Policy Compliance Statement – Title VI of the 1964 Civil Rights Act
The Tennessee Arts Commission, State of Tennessee, complies with Title VI of the Civil Rights Act of 1964, as codified in 42 U.S.C. 2000d, which states that: “No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subject to discrimination under any program or activity receiving federal financial assistance.” Annual nondiscrimination training is mandatory for all Tennessee state agency grantees as shown in contract section A.6. Each organization should have a dedicated staff person or volunteer who is monitoring Title VI compliance issues and whose name and contact information are recorded in the online grants system.
Required Annual Training
The grantee shall comply with all requirements of Title VI of the Civil Rights Act 1964, including annual training of grantee or grantee organization employees utilizing materials provided by the State. Tennessee public school grantees may meet the requirement through Title VI training system of the Tennessee Department of Education. Written documentation of training shall be maintained for a period of three (3) full years from the date of the final payment under the grant and shall be subject to audit at any reasonable time and upon reasonable notice by the state agency, the Comptroller of the Treasury or duly appointed representatives.
Who should be trained?
All paid staff involved with the grant of the organization is to be trained and this information is to be reported on the Title VI Training and Certification form. Please coordinate within your organization and submit only one form listing each staff that has completed training. Do NOT submit multiple Title VI forms for each staff person that completes training. If there are new staff members who need to receive training during the year, please contact the Title VI Coordinator for inclusion on your form.
Though not mandated, it is strongly encouraged that Board members, front line volunteers, and contractors who work with the public, also receive training.
Even if your organization receives Title VI certification through another state agency or entity, each organization must still submit a Title VI form in the Arts Commission online grants system.
Individual artists and/or individuals do not submit a Title VI certification.
K-12 public schools and public school teachers’ Title VI certification will be checked through the Tennessee Department of Education (TDOE). If the school district has not received certification through TDOE, Title VI training through the Arts Commission’s online system will be required.
In very large institutions like colleges or universities where a department or area is the grantee, please call the Title VI Coordinator for more information.
Title VI Training and 1st Requests for Payment
Title VI annual training must be completed when an organization submits its first request for payment from the Tennessee Arts Commission. All grant funds will be held until training requirements are met. If you are an Annual grant recipient who did not request an initial Request for Funds payment before December 7, 2018, your organization is still responsible for submitting a Title VI Training and Certification form no later than December 7, 2018.
Instructions for submitting Title VI Nondiscrimination Training & Certification in the Online Grants System:
To comply with the Civil Rights Act of 1964 that prohibits discrimination on the basis of race, color or national origin for entities which receive federal funds, annual nondiscrimination training is mandatory for all Tennessee state agency grantees as shown in contract section A.6. Each organization should have a dedicated staff person or volunteer who is monitoring Title VI compliance issues.
- Annual grantees must complete Title VI training after July 1, 2018, but no later than December 7, 2018, in the Online Grants System or by the first request for payment, if the request for payment is submitted prior to December 7, 2018.
- ABC Grants are required to submit Title VI training by October 1, 2018, in the online grants system. Title VI forms will be reviewed for completeness by the Designated Agency for your grant.
- Rolling Grant
- Organizations that receive Rolling Grants must submit training before payment will be distributed. If your agency has already completed the training in the TN Arts Commission’s online grant system for the FY19, it is not necessary to repeat the training. Note: if you are applying between June 1-30, 2018, FY19 Title VI training and certification form will be due after July 1 and before your project activity.
- Individuals receiving Rolling Grants do not need to complete.
- STS recipients will be verified through the Tennessee Department of Education’s Title VI requirements. If a school or district has not completed training, they will be notified and required to complete the Tennessee Arts Commission’s Title VI training.
Documentation should be kept on-site for three years.
HOW TO COMPLETE THE TITLE VI CERTIFICATION FORM:
- Log onto the Online Grants System using your Username and Password.
- In the Online Grants System’s menu bar at the left, select “Documents Library.”
- In that file, select the “FY19 Title VI Training and Certification” form and save it on your computer. The FY19 Title VI form is also accessible from the TN Art Commission’s website at www.tnartscommission.org. (Select the link in the menu on the right).
- Fill in all fields on the Title VI Training and Certification form. All staff should view one (1) of the following training options: (only pick one)
- Module I – (approximately 26 minutes)Created by the US Department of Justice several years ago, this video provides an extended overview of Title VI. The closed captioning option is not recommended since auto-generation has resulted in discrepancies in the transcription.
- Module II – (approximately 6 minutes)
Created by the US Department of Justice several years ago, Part 1 of this video provides a brief overview of Title VI and has appropriate closed captioning.
- Module III – Created by the Tennessee Arts Commission, these videos contain presentation slides on disparate treatment, disparate impact and specific examples of Title VI in arts programming.
- Module IV – (approximately 24 minutes with closed captioning available) –NEW: Created in 2010 by the US Office for Civil Rights, US Department of Health & Human Services, this video explains Title VI, Limited English Proficiency (LEP), and the use of interpreters. This video however was not specifically designed for arts organizations and the examples are not reflective of arts programming, but it does give a good overview of Title VI concepts.
- Remember: Complete only one form listing the staff who have completed training and enter the final percentage of staff trained.
- Save a copy of this form to your computer.
- Log into Online Grants System if you’re not already in and open “organization” profile.
- Hit “Edit” at the top and scroll down to “Documents.” Hit the “blue plus circle” button near Documents and upload the Title VI form.
- Before exiting the “organization” profile, hit “Save” at the bottom right-hand corner.
All grant funds will be held until training requirements are met.
TN Arts Commission’s Title VI Coordinator
If you have any questions, please contact Title VI Coordinator Kim Johnson at Kim.Johnson@tn.gov or 615-532-9797.
Reminder: Title VI Posters available
Each grantee should have a Title VI poster visible in a public location at their organization and/or event. If the organization needs copies of the Title VI poster, please contact the Art Commission’s Title VI Coordinator, or see link to the right.