Document 7678576

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Transcript Document 7678576

Limited English Proficient
(LEP)
An LEP individual is a person who is unable
to speak, read, write or understand the
English language at a level that permits
him or her to interact effectively with
health and social services agencies and
providers.
LEP and Title VI
To comply with Title
VI
federally-funded
entities must
ensure that LEP
persons
have meaningful
access.
Key to LEP Compliance
–
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To ensure
meaningful access
covered entities must:
provide language
assistance
 that results in accurate
and effective
communication
 at no cost
Meaningful Access - Factors
–
–
–
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–
size of the covered entity
size of eligible population
nature of program/service
program objectives
resources
frequency of encounters


discrete languages and
LEP individuals
Oral Language Assistance
Covered entities must provide:
– Language interpreters
– Trained & competent interpreters
– Assistance must be timely
– At no cost to the LEP person
Oral Language Assistance
Best Practice - Trained & competent interpreters:
- Minimum of 16 hrs. of training
- Training must include:
Ethical and practice standards, terminology,
interpretation skills, professional conduct, cultural
competency
- Competency:
Oral proficiency, Assessment of ethics, Integrated
interpreter skills, terminology and cultural understanding
Translator
Oral Language Assistance
Assistance Must be timely
- Same day assistance
- At no cost
Types of Oral Language
Assistance
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Bilingual staff
Staff interpreters
Contractors
Volunteers
Telephone language
line
Oral Language Assistance
Do not require
applicants/clients to:
– use family or
friends
– use minor children
Policy Guidance
“Non-applicant” family members:
immigrant family members who do not
expect to receive benefits
must not be required to disclose:
 Proof
or
 SSNs
of immigration/citizenship status;
LEP scenario #1

You are the intake worker taking care of walk-in
customers. You see a customer comes in
toward you with her young daughter
(approximately 12 years of age). The customer
approaches you at the front desk, but the
customer doesn’t talk to you, rather her
daughter start talking to you in English. Her
daughter asked you where they can go to apply
for assistance such as food and medical.
LEP scenario #2

You are an intake caseworker a customer
comes to your desk and in broken English. He
starts requesting assistance for services and
benefits. You understand part of what the
customer is saying, but you are not sure if the
customer understands you. The customer
insists that he doesn’t need an interpreter.
LEP scenario #3


Carlos’s daughter is under temporary custody by the
county agency. During the court hearing caseworkers,
Jane Doe and Mary Doe, learned that Carlos’s mother,
Isabel, was interested in obtaining permanent custody
of Carlos’s daughter. A Spanish interpreter was used
during the court hearing to communicate with Isabel.
After the court hearing, Jane and Mary Doe, met with
Isabel in three different occasions, during a period of
about five months to discuss determination of eligibility
for legal custody, home study, visitation arrangements,
completion of vital documents (in English), etc.. Isabel’s
daughter (18 years of age) was used as the interpreter
for all the meetings and also for couple of telephone
calls to the county agency.
LEP scenario #4
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
Ms. Gonzalez has been receiving food stamps, cash
assistance and Medicaid for her children. During a two
year period Ms. Gonzalez met with the county agency
staff eleven times and only in three occasions an
interpreter was provided. Ms. Gonzalez’s daughter, who
was 18 years old acted as the Spanish interpreter on
eight different occasions. To expedite her request, the
workers allowed her daughter to interpret for her.
Ms. Gonzalez received mail notification (in English) for
renewing her benefits. Ms. Gonzalez did not understand
the letter, therefore missed the appointments and also
did not provide all the required documentation to renew
her benefits. Ultimately the county agency cancelled all
of her benefits.
Written Translations
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Translate documents
into regularly
encountered
non-English languages
(when a significant
number or percentage
of the eligible
population is LEP and
needs the services or
information)
Vital Documents
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Application forms
Enrollment forms
Letters or notices
about eligibility or any
change in benefits
Anything that requires
a response
Medical or discharge
information
“Safe Harbors”
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For each language
group with fewer
than 100 persons,
the entity provides
written notice of the
right to receive oral
interpretation of
written materials in
the primary language
of the group.
“Safe Harbors”
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All written materials
are translated for each
LEP group of 10% or
3000 (whichever is
less) of the eligible
population.
Vital documents are
translated for each
LEP group of 5% or
1000 (whichever is
less) of the eligible
population.
Notice of Language
Assistance
Examples:
– Language identification cards/posters
– Signs posted in non-English languages
– Statements in non-English languages in
brochures, outreach materials, etc
– Telephonic messages in non-English languages
– Public Service Announcements
– Community outreach
Contact Information
Bureau of Civil
Rights
30 E. Broad St.,
18th Fl.
Columbus, Ohio
43215
(614) 644-2703