Legal

It is the policy of Frontier Housing, Inc. (“Frontier”) not to discriminate in the providing of its programs, activities, and services on the basis of race, color, religion, sex (including gender identity and sexual orientation), familial status, national origin, language access, age, or disability. Frontier has adopted a grievance procedure providing for prompt and equitable and fair resolution of complaints alleging any action prohibited by 40 C.F.R. Part 7 (Non-discrimination in Programs and Activities Receiving Federal Assistance from the Environmental Protection Agency), including Title VI of the Civil Rights Act of 1964, as amended; Section 504 of the Rehabilitation Act of 1973; the Age Discrimination Act of 1975; Section 13 of the Federal Water Pollution Control Act Amendments of 1972; and Title VIII of the Civil Rights Act of 1968 (Fair Housing Act). The law and regulations may be examined in the office of Frontier’s Nondiscrimination Coordinator, Chelsa Hamilton (the “Coordinator”), who has been designated to coordinate the efforts of Frontier to comply with these laws and regulations.

Any potential recipient of Frontier’s services who believes he or she has been subjected to discrimination on the basis of race, color, religion, sex (including gender identity and sexual orientation), familial status, national origin, age, or disability may file a grievance under this procedure.

Procedure:

• The complaint shall be in writing and signed by the complainant or the complainant’s representative and shall include contact information for the complainant or their representative. If the complainant is unable to write a complaint and does not have a representative who can do so on their behalf, please contact the Coordinator for assistance. The complaint shall specify with as much detail as possible:
  • The actions or inactions by Frontier that support an alleged violation;
  • The alleged discrimination that did or will result from such actions or inactions;
  • The identity of the person(s) harmed or potentially harmed by the alleged discrimination; and
  • The section of the laws or regulations that Frontier is believed to have violated.
• The complaint shall be submitted to Frontier within thirty (30) days of the event that is believed to be discriminatory, there may be instances that a waiver for good cause will be granted to extend the complaint period.

• Frontier may request additional information from the complainant if needed to assist with meeting the complaint requirements listed above. Appropriate assistance will be provided to individuals with disabilities and individuals with limited English proficiency. Also, complaints in alternate formats shall be accepted from individuals with disabilities, for example, complaints filed on computer disks, on audio tape, or in Braille.

• A letter acknowledging receipt of the complaint will be issued within ten (10) business days of its receipt by the Coordinator.

• Upon receipt of a complaint and any additional information supporting or otherwise associated with the complaint, a case file shall be established containing all documents and information pertaining to the complaint, and an initial review of the case shall be conducted.
• The Coordinator (or the Coordinator’s designee) shall conduct an investigation of the complaint. This investigation may be informal, but it will be thorough, affording all interested persons an opportunity to submit evidence relevant to the complaint. The investigation may include interviews of employees, other relevant witnesses, or others named in the complaint. Relevant employees shall make themselves available as necessary. The Coordinator will maintain the files and records of Frontier relating to such grievances.
• The Coordinator shall prepare a written report of the investigation that shall include a narrative of the incident, an identification of individuals interviewed and evidence reviewed, and findings and a determination.  Findings shall be based on a preponderance of evidence (whether it is more likely than not that discrimination occurred or did not occur). The report and determination shall be placed in the complaint file no later than thirty (30) days after its receipt, unless additional time is required to complete a thorough investigation, affording all interested persons an opportunity to submit evidence relevant to the complaint. In such case, the Coordinator shall prepare his/her written report and place it in the complaint file as soon as practically possible. 
• The findings of the investigation shall be communicated in writing to the complaining party.  The complaining party may appeal the decision of the Coordinator by submitting a written appeal to the President & CEO within fourteen (14) business days of receiving the Coordinator’s decision, (Tom Manning-Beavin, President & CEO, 5445 Flemingsburg Road, Morehead, KY  40351; phone 606-784-2131 extension 240; t.manning-beavin@frontierky.org). The President & CEO shall review the findings and the appeal and shall issue a written decision in response to the appeal within thirty (30) days after receipt of the appeal, unless the President &CEO reasonably believes that additional time is necessary to complete a thorough review of the complaint, findings, and appeal, in which case the President & CEO shall issue a written decision in response to the appeal as soon as practicable.
• The complaining party may appeal the decision of the President & CEO to Frontier’s Board of Directors by submitting a written appeal notice to Attention: Chair of the Board, 5445 Flemingsburg Road, Morehead, KY  40351 within fourteen (14) business days of receiving the President & CEO’s decision. The Board shall review the findings and the appeal and shall issue a written decision in response to the appeal within thirty (30) days after receipt of the appeal, unless the Board reasonably believes that additional time is necessary to complete a thorough review of the complaint, findings, and appeal, in which case the Board shall issue a written decision in response to the appeal as soon as practicable.  The Board’s decision shall constitute the final decision relating to the complaint and appeal.
• Should the matter of the complaint concern actions of the President & CEO, the complaining party’s appeal of the Coordinator’s findings shall be referred directly to the Board of Directors, which shall review the appeal in accordance with the preceding paragraph of this grievance procedure.
• The availability and use of this grievance procedure does not prevent any person from filing a complaint of discrimination with any federal agency authorized to administer complaints of discrimination pursuant to applicable laws and regulations, as identified in the following section, Civil Remedies, of this grievance procedure. 

Civil Remedies

• 40 C.F.R. Part 7
  • If any potential recipient of Frontier’s services believes he/she has been subjected to discrimination, he/she may file a complaint with the Environmental Protection Agency Office of Civil Rights.

• Title VI of the Civil Rights Act of 1964
  • If any potential recipient of Frontier’s services believes he/she has been subjected to discrimination, he/she may file a complaint with the U.S. Environmental Protection Agency Office of External Civil Rights.

• Age Discrimination Act of 1975
  • If any potential recipient of Frontier’s services believes he/she has been subjected to discrimination, he/she may file a complaint with the U.S. Environmental Protection Agency Office of External Civil Rights.

• Section 504 of the Rehabilitation Act of 1973
  • If any potential recipient of Frontier’s services believes he/she has been subjected to discrimination, he/she may file a complaint with the U.S. Environmental Protection Agency Office of External Civil Rights.

• Title VIII of the Civil Rights Act of 1968 (Fair Housing Act)

• If any potential recipient of Frontier’s services believes he/she has been subjected to discrimination, he/she may file a complaint with the Department of Housing and Urban Development (HUD) Office of Fair Housing and Equal Opportunity.

• Section 13 of the Federal Water Pollution Control Act Amendments of 1972
  • If any potential recipient of Frontier’s services believes he/she has been subjected to discrimination, he/she may file a complaint with the U.S. Environmental Protection Agency Office of External Civil Rights.

Anti-Relation Provision:

• Retaliation or intimidation against any person who files a complaint or participates in investigation of a complaint is prohibited and shall not be tolerated. Claims of intimidation or retaliation may be submitted pursuant to this grievance procedure and will be promptly investigated and addressed.

Accommodations:

• Frontier will make reasonable arrangements to ensure that disabled persons are provided other accommodations, if needed, to participate in this grievance process.

Access to Records:

• Records of Frontier’s discrimination complaints will be made available for review to funders, government agencies, and other interested parties as required by law, upon specific request, and subject to written authorizations and confidentiality agreements, to the extent required and/or permitted by law.

Annual Review of Procedure:

• Frontier will periodically review this grievance procedure as revise this procedure as needed to ensure prompt, efficient, and fair resolution of discrimination complaints. 

Contact Information for Coordinator:

• All written complaints shall be submitted to the Coordinator at:
  • Chelsa Hamilton
  • 5445 Flemingsburg Road, Morehead, KY  40351
  • 606-784-2131 extension 256
  • 606-784-2171 fax
  • c.hamilton@frontierky.org