Purpose and Scope 

As a recipient of federal financial assistance, the National Rural Water Association (“NRWA”) is required to comply with the federal civil rights laws that prohibit discrimination by recipients of federal funds, and to ensure that its services and benefits are provided on a nondiscriminatory basis. These laws include Title VI of the Civil Rights Act of 1964; Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990; the Age Discrimination Act of 1975; Title IX of the Education Amendments of 1972; 40 C.F.R. Parts 5 and 7; Section 13 of the Federal Water Pollution Control Act (sex); and other applicable statutes and regulations. 

NRWA has adopted this External Complaint/Grievance Resolution Procedure to assure the prompt and fair resolution of complaints alleging a violation of 40 C.F.R. Parts 5 and 7 or of any other federal civil rights law listed above. It may be used by any person who believes they have been subjected to unequal treatment, discrimination, harassment, retaliation, or intimidation by an NRWA employee or agent, or as a result of an NRWA policy or practice. 

Note: NRWA employees should refer to the NRWA employee handbook and internal policies for allegations of discrimination, harassment, or retaliation arising out of their employment with NRWA. Where an employment practice is covered by 40 C.F.R. Parts 5 or 7 — for example, where a program’s purpose is to provide employment, or where employment discrimination causes discrimination in the delivery of services to beneficiaries — the complaint will also be processed under this procedure. 

Non-Retaliation 

NRWA does not intimidate, threaten, coerce, or retaliate against any individual or group because they have exercised their rights to participate in or oppose actions protected or prohibited by federal civil rights laws, or for the purpose of interfering with such rights. Retaliation is itself a violation of these laws and may be the subject of a complaint under this procedure. 

Where to File a Complaint 

All external complaints of discrimination, harassment, retaliation, and intimidation must be forwarded immediately to the NRWA Compliance Officer, who serves as NRWA’s designated Civil Rights Coordinator under 40 C.F.R. §§ 5.135(a) and 7.85(g): 

Brian Davis 

Compliance Officer and Civil Rights Coordinator 

National Rural Water Association 

2915 S. 13th Street, Duncan, OK 73533 

Telephone: 580.252.0629  |  Toll-free: 800.332.8715 

Email: compliance@nrwa.org 

Appropriate assistance shall be provided to individuals with disabilities and individuals with limited English proficiency. Also, complaints in alternative formats shall be accepted from individuals with disabilities. Please contact the Civil Rights Coordinator listed above for more information. Complaints may be submitted in writing, by email, or orally. 

Time Limit for Filing 

Complaints should be filed within one hundred eighty (180) calendar days of the alleged discriminatory act, or within 180 calendar days after the complainant became aware of the alleged discriminatory act. The Compliance Officer may extend this period for good cause shown. 

Investigation 

The Compliance Officer is responsible for investigating complaints filed under this procedure and is committed to completing prompt and fair investigations. Each complaint will be evaluated based on a preponderance of the evidence. The Compliance Officer may consult with NRWA legal counsel at any time and may delegate the responsibilities described in this procedure to NRWA legal counsel after a complaint has been received. 

Upon receipt of a complaint, the Compliance Officer will contact the complainant to discuss the complaint and will acknowledge receipt in writing within ten (10) business days. The Compliance Officer may further: (a) request additional written documentation, (b) record the conversation for transcription purposes, and/or (c) determine whether the complaint warrants further investigation. The Compliance Officer will contact other involved parties for their statements, may interview all appropriate witnesses and the individual(s) accused of the alleged act(s), and will review documentation provided by all appropriate parties and applicable records. 

The Compliance Officer will prepare a written investigative report containing information related to witness interviews, documentation of the incident, conclusions based on the evidence, and a recommended outcome. Copies of the investigation and determination will be provided to the Chief Operations Officer for review and action, if appropriate. 

Notice of Outcome and Timeframe 

The Compliance Officer will typically complete the investigation and provide the complainant with written notice of its conclusion within one hundred twenty (120) calendar days after receiving the complaint. If additional time is required due to the circumstances of the investigation, the Compliance Officer will provide the complainant with written notice of the extension and the reason for it. 

Upon completion of an investigation, the Compliance Officer will provide the complainant with written notice that the investigation has been completed and of the outcome. The complainant will also be notified of their right to file a complaint with the appropriate state or federal agency, regardless of the Compliance Officer’s determination. 

Appeal 

If the complainant disagrees with the resolution, they may file a written appeal within fifteen (15) calendar days. The written appeal should be addressed to NRWA, Office of the CEO, 2915 S. 13^th St, Duncan, OK 73533; or executives@nrwa.org. A member of the Executive Management team will issue a final decision within 90 calendar days of receiving the appeal. 

Recordkeeping and Confidentiality 

NRWA will maintain records of complaints filed under this procedure and of their disposition for a minimum of three (3) years and make such records available to the appropriate government agency upon request. NRWA will keep the identity of complainants confidential to the extent consistent with a thorough and fair investigation, and with applicable law. 

NRWA will also collect, maintain, and on request of any federal funding agency, provide the following: 

• A brief description of any lawsuits pending against the recipient that allege discrimination which 40 C.F.R., Parts 5 & 7 prohibits 

• A log of discrimination complaints which identifies the complaint, the date it was filed, the date the recipient’s investigation was completed, the disposition, and the date of disposition, and the date of disposition 

• Reports of any compliance reviews conducted by any other agencies. 

This procedure is not intended to and does not establish a legal cause of action. Rather, it provides members of the public the opportunity to file a complaint with NRWA if they believe they have been subjected to unlawful or prohibited discrimination, harassment, retaliation, or intimidation by a representative of NRWA or as a result of its policies. Investigations are undertaken and completed in contemplation of remedial action and, in some cases, litigation, and investigative reports and associated materials are generally treated as internal records. Nothing in this paragraph limits NRWA’s obligation to provide compliance information and access to records to any federal agency as required by 40 C.F.R. § 7.85 and other applicable authorities. 

Employee Responsibilities 

NRWA employees and agents who receive verbal or written complaints from any person — including a fellow employee or agent, a member of the public, or any other person — alleging unlawful or prohibited discrimination, harassment, retaliation, or intimidation by an NRWA employee or agent against an external party are responsible for recording the information and providing it to the Compliance Officer. Allegations that are not based on unlawful or prohibited actions should be forwarded through supervisory channels to the employee’s immediate supervisor for review and action. If the employee or agent receiving the allegations is unsure whether the allegations are based on alleged unlawful or prohibited actions, the team member will contact the Compliance Officer for guidance. 

Availability of This Procedure 

This procedure is posted on NRWA’s website at [https://nrwa.org/grievance-procedure/] and is available in Spanish by toggling the language setting at the bottom of the webpage. To request this procedure in another language, or in an alternate format such as large print, Braille, audio, or accessible electronic format, contact the Compliance Officer at compliance@nrwa.org or 580.252.0629. 

Effective date: July 1, 2026  |  Last reviewed: August 18, 2026 

NRWA will review this External Complaint/Grievance Resolution Procedure at least annually and make necessary revisions to ensure prompt and fair resolution of discrimination complaints and ongoing compliance with 40 C.F.R. Parts 5 & 7, and other applicable laws and regulations.