The Catholic University of America

Compliance Obligations: Federal Non-Discrimination Statutes




Record keeping



Policy/ Assurances


Designate Employee

Civil Rights Act of 1964

Title VII: IPEDS Biennially: Fall staff survey


Records: 3 years



Faculty salary survey IPEDS


General personnel records: 1 year




Title VI:



IPEDS Enrollment



EEO poster


Spanish EEO poster


41 CFR§60-1.42

Notices to be posted


Biennially: Fall staff survey


Enrollment annually



29 CFR 1602.11 See also

20 USC 1094(a)(17)

Title VI:34 CFR 100.6

28 CFR 42.106;

45 CFR 80.6


Adoption of anti-harassment policies and complaint procedures


Internal guidelines and grievance procedures for employees and students


Voluntary affirmative action

29 CFR 1607.17


Policy compliance statement to beneficiaries and participants

Title VI; 34 CFR 100.6(d)

28 CFR 42.106;




Family & Medical Leave Act of 1993


3 years


29 CFR 825.300
DOL poster

Spanish Version DOL Poster



Written notice in employee handbooks or other witten guidance


29 CFR 825.300 (3)


Designation of type of leave

29 CFR 825.301



Equal Pay Act of 1963


2 years



EEO poster


Spanish EEO poster


29 CFR 516.4






Age Discrimination in Employment Act of 1967 (ADEA)


Payroll records:
3 years

Other records:

One year

EEO poster


Spanish EEO poster



29 CFR 1627.10


Prohibition on age related language on help wanted notices 29 CFR 1625.4





29 CFR 1625.5

Notice of non-discrimination on employment application



Title IX of Education Amendments of 1972 and


Any grievance records relating to a Title IX violation or complaint must be be retained for the period of time cited in state law for personal injury actions. In D.C. this is three years.*  Posting text* -see sample notice at end of document



Adoption of grievance procedures

34 CFR 106.8

Dissemination of Policy 34CFR§106.9, 45CFR§86.9

Publication of grievance procedures.

34 CFR 106.8
Notification of non-discrimination

To both applicants for admission and employment





Employee to coordinate compliance

34 CFR 106.8




Executive Orders 11,246 and 11,375


Who must have AA plans 41 CFR 60-1.40



41 CFR 60-1.2

2 years



Affirmative Action program

see 60-2.10 for general purpose and contents of the AA plan

EEO poster



Spanish EEO poster



41 CFR 60-1.7 is the reference to EEO-1 but for IHES what is used instead is the IPEDS fall staff survey bienially and IPEDS enrollment survey


Written affirmative action program if fed K $50,000 or more and 50 or more employees

41 CFR 60-1.7


41 CFR 60-20.6


Text for contract clause 48 CFR 52.222-26

As a federal contractor, EO notice on job postings. see41 CFR 60-1.4.



Americans with Disabilities Act of 1990

2 years for employment and 3 years for IPEDS fall staff survey

29 CFR §1602.48

29 CFR §1602.49


EEO poster


Spanish EEO poster




29 CFR 1602.7

29 CFR 1602.11


Notification to employees and applicants of the ADA policy is required


Notification to employees and applicants of the ADA policy is required


Governmental entities:

Notice to applicants, beneficiaries, participants and other interested persons

28 CFR 35.106


Officer to coordinate complaints are actually under Rehab Act Regs. 34 CFR 104.7

Rehabilitation Act of 1973


2 years

41 CFR 60-741.80

1 year if fewer than 150 employees, and no govt. contract of at least $150,000

EEO poster


Spanish EEO poster



48 CFR 52.222-36

Notice of affirmative action requirement


Internal review procedure with due process standards; affirmative action required if govt. contract $10,000 or more; written if contract $50,000 or more, and 50 or more employees

29 CFR 32.45;

Invitation to self identify Students:45 CFR 84.42


34 CFR 104.7 Officer to coordinate complaints

The Veterans' Readjustment Benefits Act

Employment records: two-years if 150 or more employees and a government contract of $150,000 or more. One year if not. 41 CFR 60-250.80

EEO poster


Spanish EEO poster




Annual by Sept. 30;

41 CFR 61-250


48 CFR 52.222-37


Written affirmative action plan if govt. K $50,000 or more, and 50 or more employees


Requires listing of all suitable jobs with local employment service

Invitation to self identify: 41 CFR 60-250.42


Equity in Athletics Disclosure Act of 1994


Equity in Athletics Report 34CFR§668.47


Equity in Athletics
Report to US Dept. of Education by Oct. 15th annually; See User's Guide for survey



Notification of availability of equity in athletics report; 34 CFR 668.47


Age Discrimination Act of 1975

Records necessary to prove compliance

45 CFR 90.45

34 CFR 110.22




Written assurance to FEDS

34 CFR 110.23


Notify of policy and responsible employee

34 CFR 110.25


34 CFR 110.25

Designate employee to coordinate compliance

Title II of the Genetics Information Nondiscrimination Act of 2008

Covered entities in possession of genetic information about applicants or employees must treat it the same way they treat medical information generally. They must keep the information confidential and, if the information is in writing, must keep it apart from other personnel information in separate medical files.

EEO Poster (updated Nov. 09 for GINA)



Spanish EEO poster



  Amend EEO policy in include non-discrimination on basis of genetic information    

Federal Tax Law



26 CFR§1.501(c)(3)(1)

Rev. Proc. 75-50


See also ACE 501(c) (3) checklist

3 year records on racial composition students and all staff. Records on award scholarships copies of all brochures, catalogues, and advertising.

Materials used to solicit $.

See chart.


Certify non-discrimination policy to IRS annually


Form 5578


Rev. Rul. 71-447, Rev. Proc. 72-54, Rev. Proc. 75-50, and Rev. Rul. 75-231,






See also USERRA, Immigration and Nationality Act; Fair Credit Reporting Act for other non-discrimination laws; Age Discrimination Act of 1975, and the Fair Housing Act.

updated 3/25/15 CCR