# Title VI assurances of the State of Minnesota *Federal nondiscrimination certifications of the State of Minnesota: subject record* This record concerns the [[Title VI]] assurances of the State of [[Minnesota]]. Its primary sources are federal. The first is a U.S. Department of Justice Office on Violence Against Women checklist of the elements a state must include in its STOP Formula Program implementation plan.[^1] The second is the U.S. Equal Employment Opportunity Commission's page on the EEO-4 State and Local Government Information Report, a federal workforce data collection from state and local governments.[^2] Neither document records a Minnesota submission. The record holds no executed Minnesota assurance. It therefore gives no date, signatory, or receiving agency for one, and no federal acceptance, review, or finding concerning one. It also holds no Minnesota EEO-4 submission or figure from one. It holds no Minnesota STOP implementation plan, approval date, or funding amount.[^1][^2] For that reason this article states no dates, dollar figures, counts, or findings for Minnesota. The sections below set out what the two federal documents require of states, and they leave the Minnesota record blank where the sources are silent. ## What The checklist, updated in April 2019, states that the STOP statute and regulations require an implementation plan as part of a state's STOP application. It cites 34 U.S.C. 10446(c)(2), (d)(5), and (i), and 28 C.F.R. 90.12 and 90.19, as the sources of the required elements.[^1] The document lists only elements that the statute and regulations require. A state may add further information to its plan.[^1] The plan's required parts are an introduction, a section on needs and context, a description of the planning process, documentation from prosecution, law enforcement, court, and victim-services programs, and a plan for a four-year implementation period.[^3][^4][^5] The EEO-4 is a separate federal requirement. The EEOC describes it as a mandatory biennial data collection. It reports workforce demographic data by race/ethnicity, sex, job category, and salary band. The EEOC states that the filing is required under section 709(c) of [[Title VII]] of the [[Civil Rights Act of 1964]], as amended, 42 U.S.C. 2000e-8(c), and 29 CFR 1602.30 and .32-.37.[^2] ## Who The checklist is addressed to STOP Administrators, to help them confirm that a plan contains every required element. The Office on Violence Against Women states that it will use a similar tool to review each state's plan.[^1] Each planning committee member must supply documentation of their participation. The listed entities are: - state sexual assault, domestic violence, or dual coalitions; - a law enforcement entity; - a prosecution entity; - a court or the state Administrative Office of the Courts; - representatives from tribes, tribal organizations, or tribal coalitions; - population specific organizations representing underserved and culturally specific populations; - other relevant individuals or entities. For each member, the documentation must show whether they were informed of meetings, attended them, reviewed drafts, submitted comments, and received the final plan.[^4] The EEO-4 must be filed by all state and local governments with 100 or more employees.[^2] ## When A STOP plan must state the date on which the state gave final approval and the time period the plan covers (28 C.F.R. 90.12(a)). It must also describe how the state will address the needs of victims over the four-year implementation period.[^3][^5] The EEO-4 collection is biennial. The EEOC publishes an EEO-4 Public Use File covering 2005 through 2023.[^6] ## How Under the needs-and-context section, a state must present demographic information drawn from the most recent available [[United States Census Bureau]] data. That information includes population data on race, ethnicity, age, disability, and limited English proficiency (28 C.F.R. 90.12(g)(1)). The state must also describe the methods it used to identify underserved populations and the results of those methods.[^3] The checklist's definition of underserved populations, citing 34 U.S.C. 12291(a)(39), includes populations underserved because of geographic location, religion, sexual orientation, and gender identity. It also includes "underserved racial and ethnic populations", populations with special needs such as language barriers, disabilities, alienage status, or age, and any other population the Attorney General determines to be underserved.[^3] Documentation from prosecution, law enforcement, court, and victim-services programs must describe four things: the need for the grant funds, their intended use, their expected result, and the demographic characteristics of the population to be served. Those characteristics include age, disability, race, ethnicity, and language background (34 U.S.C. 10446(i)(2)(C)).[^5] The plan must also describe how the state will ensure that monies set aside for culturally specific services are distributed equitably among underserved populations.[^5] For the EEO-4, the EEOC states that section 709(e) of Title VII prohibits release of individually identifiable information. Its EEOC Explore tool provides only aggregate-level data, and further statistical disclosure limitation activities protect confidential information.[^6] Data for Hawaii are reported under a different set of race/ethnic categories and are excluded from all of the aggregated tables.[^6] ## How many The STOP plan must describe how funds will be distributed across the law enforcement, prosecution, courts, victim services, and discretionary allocation categories. It must also explain how the state will meet the sexual assault set-aside, with funds allocated in two or more of the law enforcement, prosecution, victim services, and courts allocations (34 U.S.C. 10446(c)(4)–(5)).[^5] The checklist refers to a required 10% set-aside within the victim services allocation for culturally specific organizations. A state may report which subgrantees met that set-aside in the prior funding cycle.[^5] The EEO-4 threshold is 100 or more employees.[^2] ## Notes [^1]: U.S. Department of Justice, Office on Violence Against Women, *STOP Formula Program Implementation Plan Checklist* (updated April 2019) — instructions: plan required by 34 U.S.C. 10446(c)(2), (d)(5), (i) and 28 C.F.R. 90.12, 90.19; tool for STOP Administrators; OVW review with a similar tool. https://www.justice.gov/ovw/page/file/1575031/dl [^2]: U.S. Equal Employment Opportunity Commission, *EEO-4 (State and Local Government Information Report) Statistics* — introductory note: mandatory biennial collection from state and local governments with 100 or more employees; required under section 709(c) of Title VII, 42 U.S.C. 2000e-8(c), 29 CFR 1602.30 and .32-.37. https://www.eeoc.gov/data/eeo-4-state-and-local-government-information-report-statistics [^3]: U.S. Department of Justice, Office on Violence Against Women, *STOP Formula Program Implementation Plan Checklist* (updated April 2019), Parts I–II and note 1 — approval date and time period; Census-derived demographic data; underserved-population methods and definition (34 U.S.C. 12291(a)(39)). https://www.justice.gov/ovw/page/file/1575031/dl [^4]: U.S. Department of Justice, Office on Violence Against Women, *STOP Formula Program Implementation Plan Checklist* (updated April 2019), Part III — planning committee entities and required participation documentation (34 U.S.C. 10446(i)(2)(B); 28 C.F.R. 90.12(c)(2)(ii)). https://www.justice.gov/ovw/page/file/1575031/dl [^5]: U.S. Department of Justice, Office on Violence Against Women, *STOP Formula Program Implementation Plan Checklist* (updated April 2019), Parts IV–V — program documentation (34 U.S.C. 10446(i)(2)(C)); four-year plan; allocation categories; sexual assault set-aside; culturally specific 10% set-aside. https://www.justice.gov/ovw/page/file/1575031/dl [^6]: U.S. Equal Employment Opportunity Commission, *EEO-4 (State and Local Government Information Report) Statistics* — section 709(e) confidentiality; aggregate-only EEOC Explore; Public Use File 2005–2023; Hawaii excluded from aggregated tables. https://www.eeoc.gov/data/eeo-4-state-and-local-government-information-report-statistics