During the 1990s, EPA adopted a very aggressive interpretation of a provision of the 1964 Civil Rights Act which applied to state use of federal funds, Title VI.
However this provision is open to interpretation and may be understood to apply only to an entity which outsources the data processing in the first instance.
The section also includes a conflict of laws interpretation caluse that provides that if there is conflict between any provision in this section and PPACA, the provision should be interpreted as an intention to comply with federal requirement s.