California DSS Civil Rights Complaint Processes

This Policy Lab research team advises the California Department of Social Services (CDSS) in updating and improving its civil rights complaint processes. Under California and federal law, CDSS is required to provide a process through which complaints about discrimination in the provision of social services by county or state agencies can be investigated and resolved. CDSS is seeking assistance in identifying best practices to improve the current complaint processes that apply to agencies administering public benefits programs (e.g., food assistance, cash aid, childcare subsidies) and in the areas of child welfare and adult protective services.

Likely substantive areas of research include:

(1) Research that leads to recommendations about best practices for improving the complaint processes that consumers of government services may use to resolve complaints of discrimination, based upon race, color, national origin, disability, age, sex, religion, and other protected classes, intentionally or through disparate impact, or pattern and practice. Research can include analysis of other state models, including interviews with key stakeholders in those models (government employees, advocates for consumers, etc.), literature reviews and analysis, and evaluation of federal models that exist in the US Departments of Health and Human Services and Agriculture.

A sub-part of this research will be the potential role of alternative dispute resolution (ADR) models in the complaint process. Students will conduct research into the viability of including ADR into the complaint processes and make recommendations based upon this research.

Student deliverables include memoranda advising the client on effective practices for complaint processes and potentially assisting the client with drafting policy guidance and technical assistance manuals.

(2) Research regarding how to apply an equity lens to the work of CDSS and county welfare departments beyond mere civil rights compliance. What policy tools could CDSS develop and utilize to foster an affirmative equity agenda? CDSS and others are working with Government Alliance on Race and Equity (GARE), which has provided analysis and some toolkits about how to evaluate government services, procedures, and policies. Students will analyze and develop recommendations about what could be included in CDSS-issued regulations or policy guidance to counties or other service providers.

(3) The Fair Employment and Housing Council is also developing new regulations to implement Cal. Gov. Code section 11135 in tandem to CDSS’s work. These nondiscrimination regulations will apply to state-administered and state-funded programs, including those funded by CDSS and administered by county welfare departments. An ongoing working draft of these regulations is publicly available, and a meeting of the FEHC to discuss and take public comments on the working draft is expected in November or early December. Students will have the opportunity to analyze the FEHC’s current working draft regulations and advise CDSS on how the new regulatory framework interacts with and impacts CDSS’s efforts

Law students and graduate students from public policy and social science disciplines are encouraged to apply.

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Clients & Deliverables

  • Client: California Department of Social Services (CDSS)
  • Deliverables: Client briefing; policy report, Improving Civil Rights Enforcement for Californians Utilizing Public Benefits and Social Services Programs (see full report below)
    California DSS Civil Rights Complaint Processes report cover