Master SBA Non-Discrimination Compliance Policy
St. Francis Episcopal School has received a loan pursuant to the Paycheck Protection Program administered by the Small Business Administration (“SBA”). This policy is intended to demonstrate good faith compliance with the regulations issued by the SBA and by other governmental agencies enforcing the laws that attach to the School due to the School’s receipt of federal financial assistance through the SBA loan. This policy shall remain in place from the time the School receives the SBA funding until the loan is paid or forgiven.
School Compliance Officers
The School identifies the following individuals to act as its Compliance Officers under this policy:
Title IX Compliance Officer:
Don Hicks, Associate Head of School for Programs, (Title IX); DHicks@StFrancisHouston.org, 713-458-6160, 335 Piney Point Road, Houston, Texas 77024.
Section 504 Compliance Officer:
Dr. Laurie Curtis, Head of Student Support Services, (Section 504), LCurtis@StFrancisHouston.Org, 713-458-6118, 335 Piney Point Road, Houston, Texas 77024.
The Compliance Officers shall be responsible for coordinating the School’s effort to meet its responsibilities under this policy. The Compliance Officers will receive and investigate any complaints filed under this policy and make recommendations to the Head of School for the prompt and equitable resolution of complaints. The School will provide its Compliance Officers and staff appropriate training on this policy and their obligations hereunder.
Non-discrimination, Anti-harassment, Non-retaliation
The School acknowledges its obligations to prohibit discrimination, harassment, or retaliation on the basis of race, color, national origin, age, sex, disability/handicap, or religion in admission to its educational programs, activities, and services, and in employment opportunities. Retaliation against an individual for filing a complaint under this policy or participating in the informal or formal resolution is prohibited.
Academic and Non-Academic Services for Persons with Disabilities
The School remains committed to excellence in educational programming and acknowledges its obligation to ensure that no otherwise qualified individual with a disability shall, solely by reason of his/her disability, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. This includes both academic and non-academic services, such as counseling, extracurricular services, athletics, transportation, health services, recreational activities, clubs, and other activities.
The School will also assess its ability to make reasonable accommodations to disabled individuals to permit such persons to participate in and enjoy the benefits of the School’s programs and activities so long as doing so does not fundamentally alter the nature of the School’s program. Individuals who seek an accommodation should contact Dr. Laurie Curtis, Head of Student Support Services, (Section 504), LCurtis@StFrancisHouston.Org, 713-458-6118, 335 Piney Point Road, Houston, Texas 77024.
Employment Obligations for Applicants and Employees with Disabilities
The School acknowledges its obligation under the SBA regulations and laws applicable to recipients of federal financial assistance to prohibit discrimination against any employee or applicant based upon his/her disability. This obligation extends to all aspects of employment, including the hiring and employment processes.
The School will also assess its ability to make reasonable accommodations to disabled individuals so long as doing so does not create an undue hardship. Individuals who seek an accommodation should contact Dr. Laurie Curtis, Head of Student Support Services, (Section 504), LCurtis@StFrancisHouston.Org, 713-458-6118, 335 Piney Point Road, Houston, Texas 77024.
The School acknowledges its obligation under the SBA regulations to operate its programs and activities in existing facilities so they are readily accessible to qualified individuals with disabilities. The location in facilities (or movement of classes, meetings, etc. to other facilities) will be scheduled in a manner that will not knowingly deny a student, employee, parent, or visitor with a disability the opportunity to participate on the same basis as such persons without disabilities. Accommodations may be provided to allow access to educational programming or meetings.
Who may make a complaint?
A person (student, parent, employee, or applicant) may use this complaint procedure to report a concern or allegation that s/he is being denied an equal opportunity to access the School’s education programs, activities or services, including employment opportunities.
Who can a complaint be made to?
A complaint may be reported to the Compliance Officer, an Administrator, or to a staff member. Any complaint received by an Administrator or staff member shall be promptly reported to a Compliance Officer for handling.
How do you file a complaint?
A complaint may be made verbally or in writing. The School has an SBA Complaint Form available for those who choose to use it.
A complaint may also be filed with the SBA directly by sending a letter to the Administrator, Small Business Administration (SBA), Washington, D.C. 20416.
Or you can file a complaint with the Department of Education’s Office of Civil Rights (OCR). OCR’s electronic complaint form is at the following website: http://www.ed.gov/about/offices/list/ocr/complaintintro.html.
Are there timelines for filing a complaint?
Timelines are flexible, but a person with a complaint should try to report it within thirty (30) calendar days after an alleged discriminatory incident. If the complaint is filed directly with the SBA or OCR, it must be filed within 180 days of the alleged discriminatory action.
How long will it take to have a complaint handled?
While the School will try to handle the complaint as expeditiously as possible, there can be unexpected or unforeseen circumstances that cause delay. Complaints involving a handicap/disability and request for accommodation will be promptly referred to a 504 team for handling. Those complaints that require an investigation will be completed within thirty (30) days of the complaint, if possible. Should more time be required, the Compliance Officer will notify the complainant.
Informal complaint process
This policy provides an individual the option of filing an informal complaint (verbally or in writing), which allows a fuller range of options in facilitating prompt resolution of an issue(s). It is the choice of the individual complaining whether to initially pursue an informal complaint procedure. The Compliance Officer, or his/her designee, shall explore an informal resolution with the complainant, which may involve providing advice to the complainant on how to handle the issue(s) or reviewing this policy with persons involved in the issue. If the matter involves the conduct of another person, an informal resolution could involve a meeting with the complainant and that person provided both individuals agreed. Resolution through this informal procedure will be promptly explored. At any time, the complainant may request to end the informal procedure to move to the formal complaint process.
Formal complaint process
An individual may file a formal complaint (verbally or in writing) under this policy. The complainant may use the SBA Complaint Form that the School can provide or should provide the following information: a statement of the complaint that identifies the issue, provides pertinent facts, identifies those involved, and states what remedy is sought. If complainant does not provide a written statement, the Compliance Officer will prepare a statement for the complainant to review for accuracy after interviewing him/her.
The Compliance Officer, or his/her designee (“Investigator”) shall begin a formal investigation into a complaint within three (3) business days of receipt. Should the complaint allege another person engaged in discriminatory, harassing, or retaliatory conduct (“respondent”), the Investigator shall notify him/her that a complaint was filed, provide a statement of the nature of the allegations, and provide a copy of this policy and any other applicable school policy. The Investigator shall interview the complainant and any respondent as well as witnesses reasonably believed to have relevant information. The Investigator shall also consider relevant documents submitted by any person interviewed. The respondent may submit a written response to the complaint within seven (7) calendar days of being notified of the complaint.
At the conclusion of the investigation, the Compliance Officer shall submit the written report of the investigator to the Head of School/President along with recommendations as to whether and how this policy was violated and a proposed remedy for the situation.
The Head of School or his designee shall review the Compliance Officer’s report and issue a final decision, or, remand the matter back to the Investigator for further investigation. If remanded, the specific areas or issues to be investigated further shall be identified. Once the investigation is complete to the satisfaction of the Head of School, he shall issue a final written decision as to whether and how this policy was violated as well as any remedial corrective action that will be taken to redress the matter and prevent further violations. Any corrective action must be age-appropriate and timely. The decision of the Head of School shall be final and shall be communicated to the complainant and respondent separately and simultaneously as directed by the Head of School.