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Providing Services to Limited English Proficiency (LEP) fro ividua]s ht accordance with D0.1 Quidance pertaining to Title VI orthe Civil Rights Act of 1964, 42 U.S.C. C 2000d, recipients of federal financial assistance or take reasonable steps to provide memangful access to theirprograms and activities for persons with Ihnited English proficiency (-EP)- See US. Department of Justice. Guidance to Federal Financial Assistance Recpients Regarding Title VI Prohibition Against National Origin Discrimination AfFueting Limited English Proficient Persons, 67 F'ed Reg. 41;,55 (2002). For more irdormatiot on the civil rights responsibilities that recipients hate in providing language services to LR'.P in in ideals, please see the oirbsite http:/nawwAep.gov. En.sming Equal Treatment far faith -Rased Organirntions The DOJ regulation, Erpnal Treatment in Puhh-Based Organizations, 28 C.P.R. pt, 38, requires State Administering. Agencies (SAAS) to teat flith -based organizations tiie same as an) other applicant or recipient The regulation prohibits SAM foot making awnrds or grant administration decisions on flu basis of an orgmnizaton's religious character or affiliation, religious narne, or [he religious composition ofiis board of director,. "tire regulation also prohibits faith -based organizations ('roar using financial assistance (loan the DOJ to fund inherently (or explicitly) religious activities. While faith -based organizations car) engage in non - fended inherently religious activhes, they mint hold them sepa atel)- from the program Ratified by the DOJ, and recipients carnet cmup¢I beneficiaries to participeto in them. The Equal "i'reannent Regulation also makes clear that orga oratios participating in programs Funded by rite DOJ are not permitted to discriminate in the prevision of services on the basis of a beneficiary's religion. For more inforttation on the regulation, please see the OCR's websile at htyrahvww. ojp. nsdoj .gov /abau[tocn�qusrl_lrahnn. SAM and faidmbused organizations should also note that the Omnibus Crime Control and .Safe Streets Act (Sala Sucats Act) of 1968, as amended., 42 U.S.C. § 3789d(c); the Victims of Crime Act of 1984, its mnendcd, 42 U-.S.C. § f 0604(e); the,luvcnilc Justice and Delinquency Prevention Act of 1974, as unloaded, 42 U.S.C. § %72(b); and VAWA, Pub. L. hie. 119 -4, sec. 1(0)(4), 127 Star. 54, 61.62 (to be codified at 42 US C, § 13925(b)(13)) contain prohibitions against discrimination an {he basis of religion in employment. Despite {]lose nondiscrimination provisions; the DOJ has concluded that it may construe the Religious Freedom Restoration rid (R.FRA) on a case -by- vise basis to permit some fm tli �bascd orgaNzations to receive Cut funds while taking into account religion when hiring staff, even Willie statute that authorizes the binding program generally forbids recipients front considering religion in employment dccisfrrs. Please consult with the OCR f you have any questions about the regulation or the application of RFRA to the statutes that prohibit discrimination it) employment. Using Arrest and Convlefou Records in .Alaking Employment Decisions The OCR issued an advisory document It recipients on the proper use ofarrest and conviction records in looking hiring decisions. See Advisory for Recipients orhinancial Assistance from tine U.S. Department or Justice on the U.S. Equal Employment Opportunir-v Cmnntissioo's Enforcement Guidance; Consideration of Arrest and Conviction (records in Employment Decisions Under Title Vll of the Civil Rights Act of 1964 (June 2013), available at http;/Rvmv. ojp. usdoj. gov / /about /ocripdf.i/Uscof(,onvictioii Advisory. pdC Recipients should he mindful that tine trnsuae of arrestor conviction records to seven either applicants for onrployment or employces for retention or promotion may have a disparate impact based on race or national origin, resulting in unlawlid employment discrimination. In light of the Advisory, recipients should consult local counsel in ro� iewfng their employment praoliees. IPwarranted, recipients should also incorporate m) analysis of the use of nm it and conviction records in their Equal Employment Opportunity flans (hiF -OPs) (sue below), Complying with the Safe Streets Act An orgmilxadon that is a recipient of financial assistance subject to the nondiscrimination provisions of the Sari: Streets Act, most meet two obligations: (1) complying with till federal regulation pertaining to the devulopmcntof an REOP (see 28 C.F'.R_ In, 42, subpt. F,) and (2) submitting to the OCR findings of discrimination (see 28 C: F.R. §§ 41204(c), 25C -36