Requirements for Contractors

Contractors must observe all Texas Health and Human Services (HHS) policies and federal and state civil rights laws and treat our clients and the public with dignity and respect. These requirements outline how you can fulfill your contractual duties.

Things you should know:

  • What groups of people are protected by civil rights laws.
  • What posters you must display and how to inform applicants and clients about their rights.
  • How to eliminate barriers and make facilities and operations accessible to all clients.
  • How to obtain and use language services to help clients.
  • How to ensure clients get effective assistance and access to HHS services.

Civil Rights Contract Clauses

HHS agencies take steps to protect the civil rights of clients. HHS contractors and vendors are bound by the same civil rights laws as HHS agencies.

If your employees or subcontractors’ employees will have direct contact with clients, your contract contains the Civil Rights clause. Read it carefully and become familiar with the clause.

If your contact with clients involves electronic information resources (EIR), then your contract also should have a clause ensuring that these resources are accessible to people with disabilities.

To locate these clauses, contact your HHS contract manager.

What is client contact?

Civil rights laws cover all types of contact with clients. “Contact” is when you are in the presence of the client. But recently, providers have begun using websites, social media, call centers, and email to notify people about services. These are also considered “contact.”

You may not discriminate in any direct contact with clients:

  • In person
  • In written materials
  • By phone
  • On your websites or through email
  • By any other means of contact

Civil Rights Laws or Policy

Civil rights laws are created by state and federal government and provide clients protection against discrimination based on the protected classes. Protected classes are groups of people protected from discrimination. The chart below shows the laws that protect the different classes.

Protected Classes and Laws
ClassLaw Protecting Class
Race, color, national originCivil Rights Act, Title VI
DisabilityAmericans with Disabilities Act, Rehabilitation Act, Section 504
SexEducation Amendments Act, Title IX
AgeAge Discrimination Act
Religion7 CFR 16 and 45 CFR 87
Political beliefFood and Nutrition Act - only for USDA Food and Nutrition Service programs

You do not have to memorize all these laws, but you must treat people fairly, not based on bias or prejudice.

Religion involves a couple of stipulations different from the other protected classes:

  • Your program may not discriminate on the basis of religion, religious belief, or nonbelief.
  • Your program may not engage in inherently religious activities, such as worship, religious instruction, or preaching, as part of programs funded by HHS agencies. If your program conducts such activities, it must offer the activities at a separate time or location. For example, the contractor cannot require clients to participate in prayer to get HHS services.

HHS policies protecting client rights

  • HHS Circular C-001 - General policy protecting clients’ civil rights
  • HHS Circular C-013 - Language Services
  • HHS Circular C-024 - Electronic and Information Resources Accessibility

Anyone May Apply for Benefits

People who meet the requirements can get benefits and services without regard to their protected class.

Denying anyone the opportunity to apply for or get benefits and services because of that person’s protected class, even unintentionally, could be discrimination.

Contractor Responsibilities

  • Follow civil rights law.
  • Display client civil rights posters.
  • Ensure people with disabilities have access to programs and services.
  • Communicate effectively in the client’s language.
  • Ensure clients know how to file a civil rights complaint.
  • Train your staff to comply with these requirements.

Civil Rights Posters

Contractors that provide direct services to clients must display civil rights posters so they are easily visible. You can download the posters about nondiscrimination and language services from the Civil Rights Office.

Civil Rights Brochure

Another way to spread the word to clients about their civil rights, including their right to file a complaint, is to hand them an HHSC Civil Rights Office brochure.


Our clients come from different cultures and backgrounds. Contractors must treat them with dignity and respect and provide services in a fair manner. Contractors must not act on prejudice and stereotypes when serving clients because it can result in discrimination.

Customer service

People who apply for or receive HHS benefits and services are our customers. Interested third parties, such as advocates, relatives of clients, and other public officials are also our customers.

We must treat everyone with dignity and respect, politeness and attention. Customer service is a concern for civil rights because some complaints of discrimination are actually complaints about rude treatment.

Rude treatment and bad customer service:

  • May be discrimination, if based on a protected class
  • May be perceived as discrimination