Department of Labor: Partnering with Integrity 7-27-05

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    Partnering WithPartnering With

    IntegrityIntegrity

    What Faith-Based Organizations, CommunityWhat Faith-Based Organizations, Community

    Groups, and Workforce System Leaders MustGroups, and Workforce System Leaders MustKnow About U.S. Department of Labor EqualKnow About U.S. Department of Labor EqualTreatment and Religion-Related RegulationsTreatment and Religion-Related Regulations

    U.S. Department of LaborU.S. Department of Labor

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    What are the goals of the Faith-BasedWhat are the goals of the Faith-Based

    and Community Initiative (FBCI)?and Community Initiative (FBCI)?

    To expand opportunities for faith-based andTo expand opportunities for faith-based andcommunity organizations (FBCOs) to meet thecommunity organizations (FBCOs) to meet the

    social needs of Americanssocial needs of Americans To ensure the equal treatment of FBCOs in theTo ensure the equal treatment of FBCOs in the

    administration and distribution of Federaladministration and distribution of Federalfinancial assistancefinancial assistance

    To protect the religious liberty of FBCOs thatTo protect the religious liberty of FBCOs thatpartner with the Federal government and ofpartner with the Federal government and ofparticipants in Federally supported social serviceparticipants in Federally supported social serviceprogramsprograms

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    Changes to USDOL regulations andChanges to USDOL regulations and

    sub-regulatory policiessub-regulatory policies

    Goals of reforms undertaken by U.S. Department ofGoals of reforms undertaken by U.S. Department of

    Labor (USDOL):Labor (USDOL):

    Removing barriers to FBCO participation inRemoving barriers to FBCO participation inUSDOL social service programsUSDOL social service programs

    Protecting the religious liberty of:Protecting the religious liberty of:

    (1)(1) FBCOs that receive Federal financialFBCOs that receive Federal financial

    assistanceassistance

    (2)(2) participants in programs operated by theseparticipants in programs operated by these

    FBCOsFBCOs

    Regulatory changes were published in theRegulatory changes were published in the FederalFederalRe isterRe isteron ul 12, 2004on ul 12, 2004

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    Where can I find the relevant changes?Where can I find the relevant changes?

    New equal treatment regulations (29 CFRNew equal treatment regulations (29 CFRPart 2, Subpart D)Part 2, Subpart D)

    Workforce Investment Act (WIA)Workforce Investment Act (WIA)nondiscrimination and programmaticnondiscrimination and programmaticregulations (29 CFR 37.6(f); 20 CFRregulations (29 CFR 37.6(f); 20 CFR667.266 and 667.275)667.266 and 667.275)

    Job Corps regulations (20 CFR 670.555)Job Corps regulations (20 CFR 670.555)

    Job Corps Policy and RequirementsJob Corps Policy and RequirementsHandbook (PRH)Sections 6.8 (Civil andHandbook (PRH)Sections 6.8 (Civil andLegal Rights), 2.2, 3.17, 5.4 and 6.9Legal Rights), 2.2, 3.17, 5.4 and 6.9

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    The USDOL equal treatmentThe USDOL equal treatment

    regulationsregulations

    Apply to all providers that implement USDOLApply to all providers that implement USDOL

    supported social service programs, including:supported social service programs, including:

    For-profit and non-profit organizations,For-profit and non-profit organizations,

    including FBCOsincluding FBCOs

    State and local governmentsState and local governments

    One-Stop systemOne-Stop system

    Job Corps Center operators & contractorsJob Corps Center operators & contractors Govern the administration and distribution ofGovern the administration and distribution of

    USDOL supportUSDOL support

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    The USDOL equal treatmentThe USDOL equal treatment

    regulationsregulations

    Apply equally to:Apply equally to:

    USDOL supportUSDOL support

    State funds commingled with FederalState funds commingled with Federalfundsfunds

    Funds the State is required toFunds the State is required to

    contribute under a matching or grantcontribute under a matching or grant

    agreementagreement

    Embody core principles of the FBCI atEmbody core principles of the FBCI at

    USDOLUSDOL

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    Core Principles of the Faith-Based andCore Principles of the Faith-Based and

    Community Initiative at USDOLCommunity Initiative at USDOL

    I.I. Equal Opportunity for AllEqual Opportunity for All

    OrganizationsOrganizationsII.II. Respect for the Faith of Faith-Respect for the Faith of Faith-

    Based Organizations (FBOs)Based Organizations (FBOs)

    III.III. Respect for the Religious Liberty ofRespect for the Religious Liberty of

    BeneficiariesBeneficiaries

    IV.IV. Appropriate Use ofAppropriate Use ofFederalFederal SupportSupport

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    I.I. Equal Opportunity for AllEqual Opportunity for All

    OrganizationsOrganizations

    In the administration of USDOL socialIn the administration of USDOL social

    service programs:service programs:

    No organization may be discriminated for orNo organization may be discriminated for oragainst on the basis of religious character oragainst on the basis of religious character or

    affiliationaffiliation

    No eligible organization may be denied theNo eligible organization may be denied theopportunity to compete for or receive USDOLopportunity to compete for or receive USDOL

    and other Federal financial assistance basedand other Federal financial assistance based

    uponupon the organizations religious character orthe organizations religious character or

    affiliationaffiliation

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    I. Equal Opportunity for AllI. Equal Opportunity for All

    OrganizationsOrganizations

    Federal, State, or other mechanisms throughFederal, State, or other mechanisms through

    which Federal support is provided towhich Federal support is provided to

    organizations (for example, a mechanismorganizations (for example, a mechanism

    giving out vouchers for job training) must, bygiving out vouchers for job training) must, by

    law, be neutral with respect to religionlaw, be neutral with respect to religion

    Example: The entity selecting organizationsExample: The entity selecting organizations

    to be placed on a list of eligible trainingto be placed on a list of eligible trainingproviders under WIA must neither favor norproviders under WIA must neither favor nor

    disfavor an organization based on religion.disfavor an organization based on religion.

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    II. Respect the Faith of Faith-BasedII. Respect the Faith of Faith-Based

    OrganizationsOrganizations

    Faith-based organizations that receive USDOLFaith-based organizations that receive USDOLsupport may:support may:

    continue to carry out their religious activitiescontinue to carry out their religious activities

    keep religious signs or symbols in their facilitieskeep religious signs or symbols in their facilities

    continue to select their board memberscontinue to select their board members(including members of the clergy) and otherwise(including members of the clergy) and otherwisegovern themselves on a religious basisgovern themselves on a religious basis

    offer voluntary religious activities to programoffer voluntary religious activities to programparticipantskeep in mind that no directparticipantskeep in mind that no directFederal support can be used for religiousFederal support can be used for religiousactivities and these activities must be separateactivities and these activities must be separatein time or location from Federally supportedin time or location from Federally supported

    activities and voluntary for program participantsactivities and voluntary for program participants

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    III.III. Respect for the Religious Liberty ofRespect for the Religious Liberty of

    BeneficiariesBeneficiaries

    Prospective or active program participants:Prospective or active program participants:

    Must not be treated differently because of their religion orMust not be treated differently because of their religion orreligious beliefs (or lack thereof)religious beliefs (or lack thereof)

    Must be permitted to freely express their views andMust be permitted to freely express their views andexercise their right to religious freedomexercise their right to religious freedom

    Must be provided with reasonable accommodation for theirMust be provided with reasonable accommodation for their

    religious beliefs in programs; reasonableness isreligious beliefs in programs; reasonableness isdetermined on a case-by-case-basis, with regard to thedetermined on a case-by-case-basis, with regard to theparticular circumstances involvedparticular circumstances involved

    Must be informed that participation in inherently religiousMust be informed that participation in inherently religiousactivities is voluntary, and that their choice whether or notactivities is voluntary, and that their choice whether or not

    to participate will not affect the quality of the service theyto participate will not affect the quality of the service theyreceivereceive

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    IV.IV. Appropriate Use of FederalAppropriate Use of Federal SupportSupport

    What is USDOL support?What is USDOL support?

    Defined in 29 CFR 2.31(g) as Federal financialDefined in 29 CFR 2.31(g) as Federal financial

    assistance, as well as procurement funding,assistance, as well as procurement funding,provided to a non-Federal organization toprovided to a non-Federal organization tosupport the organizations administration of orsupport the organizations administration of orparticipation in a USDOL social service program.participation in a USDOL social service program.

    Includes grants, contracts, cooperativeIncludes grants, contracts, cooperative

    agreements, and other arrangementsagreements, and other arrangements Includes monetary and non-monetary assistanceIncludes monetary and non-monetary assistance

    (e.g., in-kind contributions, frequent use of(e.g., in-kind contributions, frequent use ofFederally-supported property, etc.)Federally-supported property, etc.)

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    Determined by the type of Federal supportDetermined by the type of Federal supportand how the support relates to inherentlyand how the support relates to inherentlyreligious activitiesreligious activities

    What are examples of inherently religiousWhat are examples of inherently religiousactivities?activities?

    Religious worshipReligious worship Religious instructionReligious instruction Religious proselytizingReligious proselytizing

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    To know how religion can be involvedTo know how religion can be involved

    in services provided with Federalin services provided with Federalsupport, the first question is whethersupport, the first question is whether

    the Federal support is indirectthe Federal support is indirect

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    Federal support is considered indirectFederal support is considered indirectwhen:when:

    Beneficiaries are givenBeneficiaries are given genuine,genuine,independent choicesindependent choices about where toabout where todirect the aid, including having at leastdirect the aid, including having at leastone option to which the beneficiary hasone option to which the beneficiary has

    no religious objectionno religious objection

    BeneficiariesBeneficiaries freely choosefreely choose where towhere todirect the aiddirect the aid

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    So long as the tests for indirect supportSo long as the tests for indirect support

    listed on the previous slide are satisfied,listed on the previous slide are satisfied,

    the following mechanisms can bethe following mechanisms can beconsidered indirect support:considered indirect support:

    Individual Training Accounts (ITAs)Individual Training Accounts (ITAs)

    Personal Reemployment AccountsPersonal Reemployment Accounts

    (PRAs)(PRAs)

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    Federal support is considered directFederal support is considered directunlessunless it satisfies the tests for indirectit satisfies the tests for indirectsupport (see slide 15)support (see slide 15)

    Some examples of direct Federal supportSome examples of direct Federal supportinclude:include:

    GrantsGrants

    Sub-awardsSub-awards

    ContractsContracts Cooperative agreementsCooperative agreements USDOL formula grant fundsUSDOL formula grant funds

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    There are different rules that apply toThere are different rules that apply to

    how FBCOs may use direct andhow FBCOs may use direct and

    indirect supportindirect support

    What rules apply when FederalWhat rules apply when Federal

    support is direct?support is direct?

    What rules apply when FederalWhat rules apply when Federal

    support is indirect?support is indirect?

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    When FBCOs receive indirect support, theWhen FBCOs receive indirect support, thefollowing rules apply:following rules apply:

    (1)(1) Inherently religious activities can be made anInherently religious activities can be made an

    integrated part of the regular training program.integrated part of the regular training program.Participation by the customer in these religiousParticipation by the customer in these religious

    activities is considered voluntary because it isactivities is considered voluntary because it isthe customer who has freely chosen tothe customer who has freely chosen toparticipate in the training programparticipate in the training program

    (2)(2) As a result, customers can be required toAs a result, customers can be required toparticipate fully in the training program,participate fully in the training program,including any inherently religious activitiesincluding any inherently religious activities

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    IV.IV. Appropriate Use of FederalAppropriate Use of Federal SupportSupport

    State and local areas develop standards and procedures byState and local areas develop standards and procedures bywhich organizations may qualify as Eligible Training Providerswhich organizations may qualify as Eligible Training Providers(ETPs). FBCOs that apply and that meet all requirements are(ETPs). FBCOs that apply and that meet all requirements areplaced on the ETP list.placed on the ETP list.

    Eligible Training Providers that receive indirect USDOLEligible Training Providers that receive indirect USDOLsupport through an Individual Training Account (ITA), Personalsupport through an Individual Training Account (ITA), PersonalReemployment Account (PRA), or similar mechanism may:Reemployment Account (PRA), or similar mechanism may:

    (1)(1) make inherently religious activities an integrated part ofmake inherently religious activities an integrated part of

    their regular training programtheir regular training program

    (2)(2) require customers to participate fully in their program,require customers to participate fully in their program,including any inherently religious activitiesincluding any inherently religious activities

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    Assuming the tests for indirect supportAssuming the tests for indirect support

    are satisfied, One-Stop customers mayare satisfied, One-Stop customers may

    useuse Individual Training AccountsIndividual Training Accounts (ITAs),(ITAs),

    Personal Reemployment AccountsPersonal Reemployment Accounts (PRAs),(PRAs),or similar mechanisms to purchaseor similar mechanisms to purchase

    training that (1) contains inherentlytraining that (1) contains inherently

    religious activities and/or (2) leads toreligious activities and/or (2) leads toemployment in a religious vocation.employment in a religious vocation.

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    IV. Appropriate Use of Federal SupportIV. Appropriate Use of Federal Support

    To become an Eligible Training Provider, anTo become an Eligible Training Provider, an

    organization must submit an application to theorganization must submit an application to the

    Local Workforce Investment Board, followingLocal Workforce Investment Board, following

    local procedures and deadlineslocal procedures and deadlines

    The applicable local procedures generally requireThe applicable local procedures generally require

    a description of each training program and, fora description of each training program and, for

    established programs, information on pastestablished programs, information on past

    performance and costperformance and cost

    To promote genuine choice, program descriptionsTo promote genuine choice, program descriptions

    should briefly identify any religious elementsshould briefly identify any religious elements

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    Among the provisions of Section 188 of WIA thatAmong the provisions of Section 188 of WIA thatapply to all recipients (including FBCOs) is aapply to all recipients (including FBCOs) is aprohibition on employment decisions based onprohibition on employment decisions based onreligion for positions that administer, or arereligion for positions that administer, or areconnected with, programs and activities thatconnected with, programs and activities thatreceive WIA financial assistancereceive WIA financial assistance

    Section 188Section 188 doesdoes notnot apply to employmentapply to employmentdecisions made (1)decisions made (1) beforebefore an organization firstan organization firstreceived financial assistance under WIA, or (2) forreceived financial assistance under WIA, or (2) forprograms and activities that do not receive WIAprograms and activities that do not receive WIAfinancial assistancefinancial assistance

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    The rules that apply to FederalThe rules that apply to Federalcontractorscontractors are different from those thatare different from those that

    apply to recipients of Federalapply to recipients of Federal financialfinancialassistanceassistance

    FederalFederal contractorscontractors are entities that enterare entities that enterinto agreements with the Federalinto agreements with the FederalGovernment for the purchase, sale, orGovernment for the purchase, sale, oruse of real or personal property or non-use of real or personal property or non-personal services (they arepersonal services (they are notnotgrantees)grantees)

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    IV.IV. Appropriate Use of Federal SupportAppropriate Use of Federal Support

    Nondiscrimination requirements that apply toNondiscrimination requirements that apply toFederalFederal contractorscontractors are in Executive Orderare in Executive Order(EO) 11246. Additional nondiscrimination(EO) 11246. Additional nondiscrimination

    requirements that apply to Job Corpsrequirements that apply to Job Corpscontractors can be found in 29 CFR Part 37contractors can be found in 29 CFR Part 37

    The President amended EO 11246 inThe President amended EO 11246 inDecember 2002 to permit covered FederalDecember 2002 to permit covered Federal

    contractorscontractors (not grantees) to make(not grantees) to makeemployment decisions based on religionemployment decisions based on religion

    USDOL published new rules in theUSDOL published new rules in the FederalFederalRegisterRegisterimplementing this change onimplementing this change on

    September 30, 2003September 30, 2003

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    Religion-Related Requirements forReligion-Related Requirements for

    Job CorpsJob Corps

    Job Corps Centers must take steps to protect the religiousJob Corps Centers must take steps to protect the religiousliberty of studentsliberty of students

    Job Corps Centers must not favor an organization for, orJob Corps Centers must not favor an organization for, or

    exclude an organization from, community outreach, studentexclude an organization from, community outreach, studentrecruitment and mentoring, community service, and post-Jobrecruitment and mentoring, community service, and post-JobCorps employment activities on the basis of religiousCorps employment activities on the basis of religiouscharacter or affiliationcharacter or affiliation

    Job Corps Centers must not discriminate for or againstJob Corps Centers must not discriminate for or against

    students on the basis of religion or religious beliefstudents on the basis of religion or religious beliefFBCOs that partner with Job Corps must be permitted toFBCOs that partner with Job Corps must be permitted toremain independentremain independent

    FBCOs partnering with Job Corps must not refuse to serveFBCOs partnering with Job Corps must not refuse to servestudents on account of religionstudents on account of religion

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    Religion-Related Requirements forReligion-Related Requirements for

    Job CorpsJob Corps

    The Job Corps Policy and Requirements HandbookThe Job Corps Policy and Requirements Handbook(PRH) outlines steps Job Corps Centers must take to(PRH) outlines steps Job Corps Centers must take toprotect the religious liberty of Job Corps students:protect the religious liberty of Job Corps students:

    Job Corps Centers must not discriminate for or againstJob Corps Centers must not discriminate for or againststudents on the basis of religion or religious beliefstudents on the basis of religion or religious belief

    Job Corps Centers must inform students about theirJob Corps Centers must inform students about theirreligious rightsreligious rights

    Job Corps Centers must permit voluntary religiousJob Corps Centers must permit voluntary religious

    activities, including religious services, to occur atactivities, including religious services, to occur at JobJobCorps Centers (services do not have to beCorps Centers (services do not have to benondenominational as under the prior regulation)nondenominational as under the prior regulation)

    (continued on next slide)(continued on next slide)

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    Religion-Related Requirements forReligion-Related Requirements for

    Job CorpsJob Corps

    Job Corps requirements continuedJob Corps requirements continued

    Job Corps Centers may continue to transport studentsJob Corps Centers may continue to transport studentsto local religious facilitiesto local religious facilities

    Job Corps Centers must accommodate student religiousJob Corps Centers must accommodate student religiouspractices subject to reasonable time, place, andpractices subject to reasonable time, place, andmanner restrictionsmanner restrictions

    Special rule: Where there is such government controlSpecial rule: Where there is such government control

    over the program environment that student religiousover the program environment that student religiousexercise would otherwise be significantly burdened, Jobexercise would otherwise be significantly burdened, JobCorps Centers may use direct Federal support toCorps Centers may use direct Federal support tofacilitate student-requested religious activitiesfacilitate student-requested religious activities

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    Frequently Asked QuestionsFrequently Asked Questions

    for FBCOs and the WIA Systemfor FBCOs and the WIA System

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    Q: How does an organization separate itsQ: How does an organization separate its

    religious activities from its Federally-religious activities from its Federally-

    supported social service program?supported social service program?

    A:A: Organizations that receive Organizations that receive directdirect support supportmust:must:

    (1)(1) separate inherently religious activities inseparate inherently religious activities intime or location from government-fundedtime or location from government-fundedservicesservices

    (2) carefully account for their use of all(2) carefully account for their use of allgovernment support, and ensure that Federalgovernment support, and ensure that Federal

    support is not used for inherently religioussupport is not used for inherently religiousactivitiesactivities

    (3) ensure that all inherently religious(3) ensure that all inherently religiousactivities are voluntary for program participantsactivities are voluntary for program participants

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    Q:Q: Can people who receive Federally-Can people who receive Federally-

    supported services from a provider alsosupported services from a provider also

    participate in that organizations religiousparticipate in that organizations religious

    activities?activities?

    A:A: Yes, provided that a few rules areYes, provided that a few rules are

    followed:followed:

    (1)(1) providers that receive directproviders that receive direct

    Federal support must not requireFederal support must not require

    program participants to take part in anyprogram participants to take part in any

    religious activitiesreligious activities(2)(2) employees or volunteers shouldemployees or volunteers should

    reassure the participants that they canreassure the participants that they can

    receive Federally-supported servicesreceive Federally-supported serviceseven if the do not artici ate in theseeven if the do not artici ate in these

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    Q: Can employees or volunteers of a faith-Q: Can employees or volunteers of a faith-

    based provider receiving direct Federalbased provider receiving direct Federal

    support invite program participants to joinsupport invite program participants to join

    in religious services or events?in religious services or events?

    A: Yes, provided that:A: Yes, provided that:

    (1) announcements of or invitations to(1) announcements of or invitations to

    religious services or events are handled in areligious services or events are handled in asimilar fashion to announcements orsimilar fashion to announcements orinvitations for non-religious eventsinvitations for non-religious events

    (2) the religious activities are separate in(2) the religious activities are separate in

    time or location from the Federally-time or location from the Federally-supported activitiessupported activities

    (3) the employees or volunteers make clear(3) the employees or volunteers make clearthat participation is completely voluntarythat participation is completely voluntaryand wont affect the services the participantand wont affect the services the participant

    receivesreceives

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    Q: If a program participant at an FBCO asks aboutQ: If a program participant at an FBCO asks about

    the faith of an employee or volunteer, can thethe faith of an employee or volunteer, can the

    employee or volunteer discuss his/her faith withemployee or volunteer discuss his/her faith with

    the participant?the participant?

    A: If a participant asks a programA: If a participant asks a programemployee/volunteer about his/her personal faithemployee/volunteer about his/her personal faithwhile he/she is providing a Federally-supportedwhile he/she is providing a Federally-supported

    service, the employee/volunteer may give aservice, the employee/volunteer may give ashort answer.short answer.

    If the program participant wishes to have aIf the program participant wishes to have alonger conversation on matters of faith, thelonger conversation on matters of faith, theemployee/volunteer should set up a timeemployee/volunteer should set up a timeoutside the context of the Federally-supportedoutside the context of the Federally-supportedprogram to speak with the participant.program to speak with the participant.

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    Q: Can an FBCO use direct Federal supportQ: Can an FBCO use direct Federal support

    to purchase religious materials?to purchase religious materials?

    A:A: No. Faith-based and communityNo. Faith-based and community

    organizations may not use Federalorganizations may not use Federal

    support to purchase religious materials,support to purchase religious materials,such as the Bible, Torah, Koran, Talmud,such as the Bible, Torah, Koran, Talmud,

    or other religious or scriptural materials.or other religious or scriptural materials.

    Federal support also cannot be used toFederal support also cannot be used to

    purchase materials intended forpurchase materials intended for

    inherently religious activities.inherently religious activities.

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    Q:Q: Can a faith-based organization use directCan a faith-based organization use direct

    Federal support to pay the salary of a memberFederal support to pay the salary of a member

    of its staff?of its staff?

    A:A: Yes, provided that this staff person isYes, provided that this staff person isdelivering the Federally-supporteddelivering the Federally-supportedservice and is not engaged in inherentlyservice and is not engaged in inherently

    religious activities, such as religiousreligious activities, such as religiousworship, instruction, and proselytizing,worship, instruction, and proselytizing,while working to provide the Federally-while working to provide the Federally-supported service.supported service.

    The staff member may be a rabbi, priest,The staff member may be a rabbi, priest,imam, or preacher, for example, so longimam, or preacher, for example, so longas he or she does not engage in theseas he or she does not engage in theseactivities while being paid with publicactivities while being paid with public

    dollars.dollars.

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    Q:Q: Are Individual Training Accounts (ITA) andAre Individual Training Accounts (ITA) and

    Personal Reemployment Accounts (PRA)Personal Reemployment Accounts (PRA)

    examples of indirect support?examples of indirect support?

    A: ITAs and PRAs, like vouchers, can beA: ITAs and PRAs, like vouchers, can beconsidered indirect support so long asconsidered indirect support so long as

    the tests for indirect support arethe tests for indirect support aresatisfied (also see slide 15).satisfied (also see slide 15).

    Q:Q: If a faith based group previously allowed to hireIf a faith based group previously allowed to hire

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    Q:Q: If a faith-based group previously allowed to hireIf a faith-based group previously allowed to hire

    on a religious basis becomes a recipient of WIAon a religious basis becomes a recipient of WIA

    financial assistance, will the organization havefinancial assistance, will the organization have

    legal problems related to its previous hiringlegal problems related to its previous hiring

    decisions?decisions?

    A: No. The law does not apply retroactively.A: No. The law does not apply retroactively.

    The WIA nondiscrimination provisionsThe WIA nondiscrimination provisions

    will apply only to the activities in which awill apply only to the activities in which afaith-based organization engages after itfaith-based organization engages after it

    becomes a recipient under WIA, and onlybecomes a recipient under WIA, and only

    to jobs that administer or are connectedto jobs that administer or are connected

    with the programs and activities thatwith the programs and activities thatreceive the Federal financial assistance.receive the Federal financial assistance.

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    Legal Guidance for FBCOs and the WIALegal Guidance for FBCOs and the WIA

    SystemSystem

    White House Office of Faith-Based and CommunityW te House O ce o Fa t -Base an Commun tyInitiativesInitiatives

    www.whitehouse.gov/government/fbci/guidance/index.htwww.whitehouse.gov/government/fbci/guidance/index.ht

    USDOL Center for Faith-Based and Community InitiativesUSDOL Center for Faith-Based and Community Initiatives

    www.dol.gov/cfbci/legalguidance.htmwww.dol.gov/cfbci/legalguidance.htm

    USDOL Civil Rights CenterUSDOL Civil Rights Center

    www.dol.gov/oasam/programs/crc/crcwelcome.htmwww.dol.gov/oasam/programs/crc/crcwelcome.htm

    Job Corps PRH Websiteob Corps PRH Website

    jobcorps.doleta.gov/docs/prh.pdfobcorps.doleta.gov/docs/prh.pdf

    http://www.whitehouse.gov/government/fbci/guidance/index.htmlhttp://www.whitehouse.gov/government/fbci/guidance/index.htmlhttp://www.whitehouse.gov/government/fbci/guidance/index.htmlhttp://www.whitehouse.gov/government/fbci/guidance/index.html