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County staff outline Title VI compliance steps as federal ER funds pass through to Clay County
Summary
Commissioners were briefed that federal ER grant funds recently routed to Clay County require Title VI nondiscrimination assurances, a designated coordinator, complaint procedures and contract language; staff said documents and a proposed coordinator will be presented next week.
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County staff told the commission that recent Emergency Relief (ER) funding tied to last year’s flooding will be passed through to Clay County and that the pass-through triggers federal Title VI requirements. Speaker 2 said the county must adopt Title VI policies, designate a Title VI coordinator, implement a complaint procedure for the public, prepare a public involvement plan, and include Title VI assurances in agreements and subcontracts that use federal aid.
"They were telling us for the first time ever that we needed to have a Title VI policy, a Title VI coordinator, a complaint procedure for handling Title VI complaints from the public, public involvement plan or policy...and non-discriminatory practice for hiring," Speaker 2 said. Staff explained that historically the state absorbed much of these compliance actions but because the federal funds are being routed directly to the county in this instance, the county now bears the obligation.
Speakers said they are preparing policy templates and forms adapted from state materials and expect to bring formal documents to the commission next week so the county can formally receive the grant. Staff discussed possible designees for the coordinator role—naming Brent and Lane as operational candidates to handle paperwork and oversight—and said the initial compliance work will apply specifically to the ER-funded project. If scope expands, the county may reconsider assignment.
The commission discussed that the state has a detailed handbook and that some state-level practices (for example, working with tribal governments) may not map directly to the county’s responsibilities, but staff said the county can generally adapt state templates for its use. The board did not take a formal vote on this item at the meeting but instructed staff to finalize the Title VI documents for next-week consideration.

