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## Language Assistance and Planning Self-Assessment Tool for Recipients of Federal Financial Assistance

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**Purpose**

This two-part document is intended to assist organizations that receive
Federal financial assistance in their strategic planning efforts to
ensure that program goals and objectives address meaningful access for
all of the people they serve or encounter, including those who are
limited-English proficient (LEP). This tool will assist recipients in
assessing their current other-than-English language service capabilities
and in planning for the provision of language assistance to LEP
individuals they serve or encounter. As recipients develop performance
measures to assist them in evaluating the effectiveness of their program
and program delivery, by using this tool, they will be able to assess
the effectiveness of performance measures relative to individuals who
are LEP.

Part A provides a framework for the development of a Language Assistance
Plan in light of the general Title VI requirements. The planning and
self-assessment questions in Part B of this document, intended as a
follow-up to Part A, are guided by the requirements of Title VI of the
Civil Rights Act of 1964, as amended, and Title VI regulations, as set
forth in 29 CFR Part 31; Section 188 of the Workforce Investment Act
(WIA) and its implementing regulations at 29, CFR Part 37 (available on
CRC's website at <http://www.dol.gov/oasam/programs/crc/>).

**Introduction**

**Executive Order No. 13166**

Executive Order No. 13166, \"Improving Access to Services for Persons
with Limited English Proficiency,\" (available electronically at
<http://www.dol.gov/oasam/regs/statutes/Eo13166.pdf>) was created to
\"\... improve access to Federally conducted and Federally assisted
programs and activities for persons who, as a result of national origin,
are limited in their English proficiency (LEP)\...\" President Bush
affirmed his commitment to Executive Order 13166 through a memorandum
issued on October 25, 2001, by Assistant Attorney General for Civil
Rights, Ralph F. Boyd, Jr. Federal agencies were directed to provide
guidance and technical assistance to recipients of Federal funds as to
how they can provide meaningful access to LEP users of Federal programs.
In addition, Federal agencies were told to look at how they served
people who were limited in their English proficiency and to see what
measures they could take in their direct contacts with LEP individuals
that would increase meaningful access. In addition, a Federal
Interagency Workgroup on Limited English Proficiency was formed to
coordinate guidance and technical assistance efforts throughout the
Federal government in support of Executive Order 13166. One of the
Workgroup\'s first accomplishments was the creation of a Federal web
site ([http://www.lep.gov](http://www.lep.gov/)). The site is a work in
progress and is designed to be a one-stop referral shop for recipients,
Federal agencies, and communities in the quest for LEP information and
technical assistance. It is through the coordinated efforts of the
Workgroup that this planning and self-assessment tool was created.

**Title VI of the Civil Rights Act of 1964**

The basis for Executive Order 13166 is Section 601 of Title VI of the
Civil Rights Act of 1964, 42 U.S.C. 2000d, (hereinafter Title VI), which
provides that no person shall \"on the ground of race, color, or
national origin, be excluded from participation in, be denied the
benefits of, or be subjected to discrimination under any program or
activity receiving Federal financial assistance.\" Section 602
authorizes and directs Federal agencies that are empowered to extend
Federal financial assistance to any program or activity \"to effectuate
the provisions of \[section 601\] ...by issuing rules, regulations, or
orders of general applicability.\" 42 U.S.C. 2000d-1. WIA Section 188
mirrors the requirements of Title VI.

The Supreme Court, in *Lau* v. *Nichols*, 414 U.S. 563 (1974), affirmed
then Department of Health, Education, and Welfare (HEW) policy (in line
with HEW\'s Title VI regulation which is similar to that of DOJ, 45 CFR
80.3(b)(2)), stating that a recipient\'s failure to ensure meaningful
opportunity to national origin minority, limited-English proficient
persons to participate in the Federally funded program violates Title VI
and Title VI regulations. In the *Lau* case, a San Francisco school
district that had a significant number of non-English speaking students
of Chinese origin was required to take reasonable affirmative steps to
provide them with a meaningful opportunity to participate in the
Federally funded education program. The requirement to provide
meaningful access under Title VI applies beyond the education context to
include all of the programs and activities of all recipients of Federal
financial assistance.

**Limited English Proficiency**

**Self-Assessment Tool**

**Part A: Developing a Language Assistance Plan**

This section is intended to provide a general overview for the
development of a Language Assistance Plan for LEP beneficiaries or
potential beneficiaries. Each Federal recipient may choose to develop a
Language Assistance Plan differently. Regardless of the format selected,
careful consideration should be given to whether their Language
Assistance Plan is sufficiently detailed to address the questions set
forth in the self-assessment (Part B,).

Recipients have considerable flexibility in developing a Language
Assistance Plan. The development and maintenance of a
periodically-updated Language Assistance Plan for use by recipient
employees serving the public will likely be the most appropriate and
cost-effective means of documenting compliance and providing a framework
for the provision of timely and reasonable language assistance.
Moreover, such written plans would likely provide additional guidance to
a recipient\'s managers in the areas of training, administration,
planning, and budgeting. These benefits should lead most recipients to
document in a written Language Assistance Plan their language assistance
services, and how staff and LEP persons can access those services.
Despite these benefits, certain recipients, such as those serving very
few LEP persons and recipients with very limited resources may choose
not to develop a written LEP plan. However, the absence of a written LEP
plan does not obviate the underlying obligation to ensure meaningful
access for LEP persons to a recipient\'s programs or activities.
Accordingly, in the event that a recipient elects not to develop a
written plan, it should consider alternative ways to articulate, in a
reasonable manner, a plan for providing meaningful access. Entities
having significant contact with LEP persons, such as schools, religious
organizations, community groups, and groups working with new immigrants
can be very helpful in providing important information into this
planning process from the beginning.

Good Language Assistance Plans should be:

1.  Based on sound planning;

2.  Adequately supported so that implementation has a realistic chance
    of success; and

3.  Periodically evaluated and revised, if necessary.

The first topic covered in this part is the establishment of goals in a
Language Assistance Plan. The second topic in this part is a brief
overview of points that may be considered in developing a comprehensive
Plan.

**Section I: Goals**

The process of developing goals flows directly from the self-assessment
that has been conducted. Goals should reflect the recipient's
circumstances. It is recommended that the recipient's design be based,
at least in part, on the results of focused research and benchmarking
and on best practices identified by community organizations, other
Federal recipients, professional organizations, advocacy groups, and
experts in the language assistance field.

The fundamental Title VI requirement is that Federal recipients ensure
meaningful access for LEP individuals to the Federal recipient\'s
programs and activities. Therefore, the goals for the provision of
language assistance to LEP individuals should relate to a thorough
assessment of the target population for each program and activity, the
geographical location where the programs and activities will take place,
and the expected outcome(s) of the programs and activities.

Generally, goals that are effective indicate:

-   to whom they apply;

-   the expected outcome;

-   when the outcome is expected to materialize; and

-   how success will be measured.

Effective goals for the provision of language assistance to LEP
individuals address the language as well as the cultural context within
which the service is provided. To enhance language assistance
capabilities, recipients may also choose to have goals in such areas as
basic language training for staff, language assistance policy design and
implementation, and outreach initiatives for language isolated
communities.

**Section II: Planning**

Many Federal recipients have found that it is useful, when developing or
revising a Language Assistance Plan, to establish a committee or work
group that includes administrators, professional and administrative
support staff, potential beneficiaries, and members of community
organizations. By working with a diverse group that includes
stakeholders, recipients can gather comprehensive input from those whose
support and efforts may be important to their Language Assistance Plan's
success. Inclusive approaches in plan design and development tend to
promote overall community awareness and support. In addition, these
groups will be valuable resources to draw upon during plan evaluation
and plan improvement activities.

One of the first steps toward developing a plan is to take the
information the recipient has gained through the self-assessment (Part
B), combine it with the recipient's goals, and convert it into a viable
plan or roadmap that helps the recipient identify and address gaps,
while at the same time moves the organization towards a coordinated and
comprehensive approach to meeting its needs.

Have you developed a comprehensive plan for language assistance to LEP
persons?

 YES  NO

If not, or if you just want more information to consider in assessing
the comprehensiveness of your already existing plan, there are some
useful pointers on
<http://www.dol.gov/oasam/regs/fedreg/notices/2003013125.pdf> as well as
on [www.lep.gov](http://www.lep.gov/).

Briefly, in designing a comprehensive Language Assistance Plan the
recipient should follow the following five steps: 1) Identification of
LEP Persons; 2) Language Assistance Measures; 3) Training Staff; 4)
Providing Notice to LEP Persons; and 5) Monitoring and Updating the
Language Assistance Plan.

1\. *Identification of LEP Persons*

This first step comprises the recipient's consideration of the
information obtained from the first two self-assessment factors: the
number or proportion of LEP individuals eligible to be served or
encountered, and the frequency of encounters. This information
identifies LEP persons with whom the recipient has had, or could have
contact.

In refining the recipient's assessment of the target LEP population, the
recipient can use language identification cards (or \"I speak cards\"),
which invite LEP persons to identify their language needs to staff. Such
cards, for instance, might say \"I speak Spanish\" in both Spanish and
English, \"I speak Vietnamese\" in both English and Vietnamese, etc. The
recipient can access examples of such cards, at no cost on the Internet
at <http://www.dol.gov/oasam/programs/crc/ISpeakCards.pdf>, and also at
[www.lep.gov](http://www.lep.gov/). In addition, when records are kept
of interactions with members of the public, the language of the LEP
person can be included as part of the record. In addition, posting
notices in commonly encountered languages notifying LEP persons of
language assistance will encourage them to self-identify.

2\. *Language Assistance Measures*

In developing an effective Language Assistance Plan, the recipient
should also consider including information about the ways language
assistance will be provided. For instance, the recipient may want to
include information on:

-   Types of language services available;

-   How staff can obtain those services;

-   How to respond to LEP callers;

-   How to respond to written communications from LEP persons;

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-   How to respond to LEP individuals who have in-person contact with
    staff; and

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-   How non-Greek alphabet words will be entered into the computer
    systems.

3\. *Training Staff*

It is essential for the members of the recipient's organization to be
knowledgeable about the organization\'s obligations to provide
meaningful access to information and services for LEP persons. It is,
therefore, recommended that the recipient's Language Assistance Plan
include training to ensure that:

-   Staff know about LEP policies and procedures.

-   Staff having contact with the public (or those in a recipient\'s
    custody) are trained to work effectively with in-person and
    telephone interpreters.

The recipient may want to include Language Assistance Plan training as
part of the orientation for new employees. The more frequent the contact
with LEP persons, the greater the need will be for in-depth training.
The manner in which the training is provided is within the
organization\'s discretion.

4\. *Providing Notice to LEP Persons*

Once the recipient has decided, based on the four-factor self-assessment
in Part A, that provision of language services will be implemented, it
is important to let LEP persons know that those services are available
and that they are free of charge. The recipient should provide this
notice in a language LEP persons will understand. Some ways of
accomplishing this objective include:

-   Posting signs in intake areas and other entry points.

-   Placing notices that that language services are available in
    outreach documents (brochures, booklets, recruitment information,
    etc.) in appropriate languages that language services are available.

-   Working with community-based organizations to inform LEP persons of
    the language assistance available.

-   Using a telephone voicemail menu in the most common languages
    encountered.

-   Including notices in local newspapers in languages other then
    English.

-   Providing notices in non-English language radio and television
    stations about the availability of language assistance services.

-   Making presentations and/or posting notices at schools and religious
    organizations.

5\. *Monitoring and Updating* *the* *Language Assistance Plan*

The recipient should, where appropriate, have a process for determining,
on an ongoing basis, whether new documents, programs, services, and
activities need to be made accessible for LEP individuals, and provide
notice to the LEP public and to employees of any changes in programs or
services. In addition, the recipient should consider whether changes in
demographics, types of services, or other needs require annual
re-evaluation of your Language Assistance Plan.

One good way to evaluate a Language Assistance Plan is to seek feedback
from the community, and assess potential plan modifications based on:

-   Current LEP populations in service area or population encountered or
    affected;

-   Frequency of encounters with LEP language groups;

-   Nature and importance of activities to LEP persons;

-   Availability of resources, including technological advances,
    additional resources, and the costs imposed;

-   Whether existing assistance is meeting the needs of LEP persons;

-   Whether staff know and understand the Language Assistance Plan and
    how to implement it; and

-   Whether identified sources for assistance are still available and
    viable.

Exemplary practices and further policies with regard to written Language
Assistance Plans can be found at
[http://www.lep.gov](http://www.lep.gov/). The following questions are
designed to assist in assessing the recipient's planning needs.

a\) Does your organization have a written policy on the provision of
language interpreter and translator services?

 YES  NO

b\) If so, is a description of this policy available to the general
public?

 YES  NO

If so, how and when is the policy available?

In what languages other than English is the written policy on language
interpreters and translation services available?

c\) Do you inform your employees of your policies regarding LEP persons?

 YES  NO

If so, how? How often?

d\) Do you inform your subcontractors of your policies regarding LEP
persons?

 YES  NO

If so, how? How often?

e\) Do you inform your subcontractors of their obligation to provide
language assistance to LEP individuals who participate in their programs
and activities and/or who use their services provided?

 YES  NO

If so, how? How often?

f\) Do your subcontractors have a written policy on the provision of
language interpreter and translator services?

 YES  NO

g\) If so, is it distributed to the general public?

 YES  NO

h\) If so, when and how is it made available?

i\) In what languages, other than English, is it made available?

j\) Are beneficiaries informed that they will be provided interpreting
services at no cost?

 YES  NO

k\) How are they informed and at what points of contact?

l\) Do you ensure that your translators and/or interpreters are
qualified to provide interpreting services (which is a different skill
than being bilingual) and understand any confidentiality requirements?

 YES  NO

If so, how?

m\) Is ability to speak a language other than English a factor in hiring
decisions in your organization?

 YES  NO

If so, how do you identify which languages are needed?

n\) Do you ensure that your bilingual staff are qualified to provide
services in another language?

 YES  NO

If so, how? How often is it reviewed or re-evaluated?

o\) List the written materials that you provide to the public.

p\) Do you provide written materials to the public in languages other
than English?

 YE YES  NO

If so where are they located?

q\) Is the public notified of the availability of the translated
materials?

 YES  NO

r\) List all written materials provided to the public in languages other
than English and the languages for which they are available.

s\) Are there set criteria for deciding:

Which materials will be translated?

 YES  NO

Who will translate the materials?

 YES  NO

How you will assess competency to translate?

 YES  NO

Who will provide a second check on the translation?

>  YES  NO

Into which language(s) will the materials be translated?

>  YES  NO

t\) Are all translated materials pre-tested before they are finalized?

 YES  NO

If no, which materials are not pre-tested and why?

**Section III: Language Assistance Plan** **Evaluation**

The following information is provided to assist the recipient in
identifying methods and approaches for evaluating a Language Assistance
Plan. The recipient is encouraged to review the Language Assistance Plan
annually and to develop approaches for evaluation that are consistent
with the respective Language Assistance Plan designs, organizational
needs, and circumstances. The evaluation process creates quality
feedback for recipient's organization. Also, the evaluation process can
be used as a sentinel to detect problems before they grow, and to
confirm best practices.

Federal law does not prescribe a particular program model or evaluation
approach; therefore, the approach to, and design of, an effective
Language Assistance Plan evaluation will vary for each Federal
recipient. The questions set forth below are provided as primers for the
recipient to use in developing an approach.

1\. Do you have and use a tool for collecting data on beneficiary
satisfaction with interpreter services?

 YES  NO

2\. Have any grievances or complaints been filed because of language
access problems?

 YES  NO

If so, with who?

3\. Do you monitor the system for collecting data on beneficiary
satisfaction and/or grievance/complaint filing?

 YES  NO

If so, how? How often?

4\. Is data used as part of a review by senior management of the
effectiveness of your organization\'s language assistance program
implementation?

 YES  NO

5\. Do you regularly update your Language Assistance Plan and assess for
modifications given changing demographics, or changes or additions to
your programs?

 YES  NO

If so, how? How often?

6\. Do you obtain feedback from the community?

 YES  NO

If so, how? How often?

Generally, organizations measure \"success\" in terms of whether a plan,
when implemented, leads to the achievement of the particular goals the
organization has established. If the organization has established no
particular goals, it can still be successful if the results are in
concert with the organization\'s desired outcomes. In this case, the
desired outcome is the provision of language assistance, when necessary,
to ensure that LEP persons are able to participate meaningfully in the
Federal recipient's programs and activities.

The recipient should modify the Language Assistance Plan if it proves to
be unsuccessful after a legitimate trial. As a practical matter, the
recipient may not be able to comply with this Title VI requirement
unless it periodically evaluates the Plan.

**Part B: Self-Assessment**

The questions in this part are intended for use by recipients of Federal
financial assistance in conducting a self-assessment of their progress
in providing language assistance to LEP persons. The questionnaire is
divided into four sections and is designed to assist in a balanced
assessment of access based on the following four factors: (1)
Demography - the number or proportion of LEP persons eligible to be
served or likely to be encountered; (2) Frequency of Contact - the
frequency with which LEP individuals come in contact with the program
and/or activities; (3) Importance - the nature and importance of the
program, activity, or service to people's lives; and (4) Resources-the
resources available and costs.

**Section I -- Demography**

The determination to provide language assistance services should include
an assessment of the number or proportion of LEP persons from a
particular language group served, or encountered in the eligible service
population. The greater the number or proportion of LEP persons served
or encountered, the more likely language services are needed.

According to the 2000 Census, Profile of Selected Social
Characteristics, Supplementary Survey Summary (Table QT-02), English is
the only language spoken at home by an estimated 82.4% (209,860,377) of
the population 5 years of age and over (254,746,174). The remaining 17.6
percent (44,885,797) speak a language other than English at home. Of
those U.S. residents five years of age and older who speak a language
other than English at home, the same Census 2000 Survey estimates that
43.4 percent (19,492,832) speak English "less than very well." For these
people---approximately 7.7 percent of the total population of persons
five years of age or older---language can be a barrier to obtaining
meaningful access to programs and activities conducted, or services or
information provided by recipients of Federal financial assistance.

There are a variety of sources for demographic information. As noted
immediately above, the Bureau of Census is one potential source.
Detailed information about the racial and ethnic populations a recipient
serves or might serve, including their languages, can also be inferred
from Department of Education data. A recipient can link directly to the
Bureau of the Census, Department of Education, and other demographic
data through [http://www.lep.gov](http://www.lep.gov/) by selecting the
Demographic button.

The following questions are aimed at identifying who the recipient
serves. Please note that the term "serve" is used to include not only
those who are often considered direct beneficiaries or recipients of
government programs and activities, but also those individuals at a
Workforce Investment Act One-Stop Center that may only use
self-services. Job Corps recipients should also consider LEP parents' or
guardians' access when their English proficient or LEP minor children
and dependents encounter their programs, activities, or services.

1\. Has your organization developed a demographic profile of the
population served or likely to be served by your DOL funded programs and
activities?

YES  NO

If no, consider utilizing the demographic information from the U.S.
Census Bureau available for your particular geographical area (see the
following sample data sheet) available at
<http://quickfacts.census.gov/qfd/index.html>.

2\. Where the service area your program serves spans multiple labor
market areas, have demographic profiles been developed for each labor
market or local area?

YES  NO

If no, consider utilizing the demographic information from the U.S.
Census Bureau available for your particular geographical area (see the
following sample data sheet) available at
<http://quickfacts.census.gov/qfd/index.html>.

3\. Has your organization developed a profile of the primary languages
spoken by the population served or likely to be served by your Federally
funded programs and activities?

 YES  NO

If no, you can begin to develop such a profile now by going directly to
[http://www.doleta.gov/reports/CensusData/](http://www.doleta.gov/reports/CensusData/ )
or to [www.lep.gov](http://www.lep.gov/) in order to access demographic
data including LEP statistics. In addition to the Census, you can
identify and clarify language needs by calling on the Department of
Education or community-based organizations in your service area.

***Question 2 -*** ***Sample***

  ------------------- ------------ ------------- ------------ ------------- ------------ ------------- ------------ ------------- ------------ -------------
  **Table 2. Ability                                                                                                                           
  to Speak English by                                                                                                                          
  Language Spoken at                                                                                                                           
  Home**                                                                                                                                       

  **Universe:**                                                                                                                                
  Population 18 years                                                                                                                          
  and over                                                                                                                                     

  **Geography:**      **New                                   New Mexico                                                          35040        **LWIA#**
                      Mexico**                                Eastern Area                                                                     

                                                                                                                                               

  **Language Spoken   **Speak                    **Speak                    **Speak                    **Speak                    **Total**    
  at Home**           English                    English                    English                    English                                 
                      \"very                     \"well\"**                 \"not                      \"not at                                
                      well\"**                                              well\"**                   all\"**                                 

                      **Number**   **Percent**   **Number**   **Percent**   **Number**   **Percent**   **Number**   **Percent**   **Number**   **Percent**

  **Total population  \(X\)        \(X\)         \(X\)        \(X\)         \(X\)        \(X\)         \(X\)        \(X\)         239,155      100.0
  18 and over**                                                                                                                                

  Speak only English  \(X\)        \(X\)         \(X\)        \(X\)         \(X\)        \(X\)         \(X\)        \(X\)         166,720      69.7

  Speak language      46,150       63.7          13,845       19.1          8,525        11.8          3,915        5.4           72,435       30.3
  other than English                                                                                                                           

  African languages   15           50.0          15           50.0          0            0.0           0            0.0           30           0.0

  Arabic              35           58.3          25           41.7          0            0.0           0            0.0           60           0.0

  Armenian            0            .             0            .             0            .             0            .             0            0.0

  Chinese             205          50.0          125          30.5          50           12.2          30           7.3           410          0.2

  French (incl.       385          79.4          60           12.4          40           8.3           0            0.0           485          0.2
  Patois, Cajun)                                                                                                                               

  French Creole       0            .             0            .             0            .             0            .             0            0.0

  German              1,190        55.4          645          30.0          300          14.0          15           0.7           2,150        0.9

  Greek               20           71.4          4            14.3          4            14.3          0            0.0           28           0.0

  Gujarathi           25           31.7          20           25.3          30           38.0          4            5.1           79           0.0

  Hebrew              25           86.2          4            13.8          0            0.0           0            0.0           29           0.0

  Hindi               75           75.8          20           20.2          4            4.0           0            0.0           99           0.0

  Hungarian           20           83.3          4            16.7          0            0.0           0            0.0           24           0.0

  Italian             90           90.0          10           10.0          0            0.0           0            0.0           100          0.0

  Japanese            220          86.3          35           13.7          0            0.0           0            0.0           255          0.1

  Korean              70           42.4          65           39.4          30           18.2          0            0.0           165          0.1

  Laotian             4            7.4           50           92.6          0            0.0           0            0.0           54           0.0

  Miao, Hmong         0            .             0            .             0            .             0            .             0            0.0

  Mon-Khmer,          0            .             0            .             0            .             0            .             0            0.0
  Cambodian                                                                                                                                    

  Navajo              145          69.1          40           19.1          25           11.9          0            0.0           210          0.1

  Other and           25           75.8          0            0.0           4            12.1          4            12.1          33           0.0
  unspecified                                                                                                                                  
  languages                                                                                                                                    

  Other Asian         80           85.1          10           10.6          4            4.3           0            0.0           94           0.0
  languages                                                                                                                                    

  Other Indic         65           82.3          4            5.1           10           12.7          0            0.0           79           0.0
  languages                                                                                                                                    

  Other Indo-European 35           100.0         0            0.0           0            0.0           0            0.0           35           0.0
  languages                                                                                                                                    

  Other Native North  625          80.1          155          19.9          0            0.0           0            0.0           780          0.3
  American languages                                                                                                                           

  Other Pacific       50           58.8          35           41.2          0            0.0           0            0.0           85           0.0
  Island languages                                                                                                                             

  Other Slavic        25           100.0         0            0.0           0            0.0           0            0.0           25           0.0
  languages                                                                                                                                    

  Other West Germanic 50           63.3          25           31.7          4            5.1           0            0.0           79           0.0
  languages                                                                                                                                    

  Persian             0            0.0           10           100.0         0            0.0           0            0.0           10           0.0

  Polish              35           50.7          30           43.5          4            5.8           0            0.0           69           0.0

  Portuguese or       55           55.6          40           40.4          4            4.0           0            0.0           99           0.0
  Portuguese Creole                                                                                                                            

  Russian             20           50.0          10           25.0          10           25.0          0            0.0           40           0.0

  Scandinavian        25           50.0          15           30.0          0            0.0           10           20.0          50           0.0
  languages                                                                                                                                    

  Serbo-Croatian      15           100.0         0            0.0           0            0.0           0            0.0           15           0.0

  Spanish or Spanish  42,095       63.7          12,170       18.4          7,935        12.0          3,845        5.8           66,045       27.6
  Creole                                                                                                                                       

  Tagalog             290          61.7          145          30.9          35           7.5           0            0.0           470          0.2

  Thai                80           55.6          30           20.8          30           20.8          4            2.8           144          0.1

  Urdu                4            13.8          25           86.2          0            0.0           0            0.0           29           0.0

  Vietnamese          25           86.2          4            13.8          0            0.0           0            0.0           29           0.0

  Yiddish             15           100.0         0            0.0           0            0.0           0            0.0           15           0.0
  ------------------- ------------ ------------- ------------ ------------- ------------ ------------- ------------ ------------- ------------ -------------

3\. Is your organization working with any community-based organizations
that are familiar with the language needs of individuals participating
in any of your programs and activities, or to whom you provide services
or encounter?

 YES  NO

4\. If applicable, are local workforce areas, local offices, Job Corps
Centers, Unemployment Service Centers, or sub-recipients working with
any community-based organizations that are familiar with the language
needs of individuals participating in any of your programs and
activities, or to whom you provide services or encounter?

 YES  NO  Not Applicable

Once the recipient has completed an overview and identified general
demographic data, it is in a better position to move to an analysis of
the language access the recipient provides to the people it serves.

**Section II- Frequency of Contact**

The following questions are designed to help recipients assess the
frequency with which LEP individuals are contacted or encountered and
their respective language groups The more frequent the contact with a
particular language group, the more likely that enhanced language
services in that language are needed. It is also advisable to consider
the frequency of different types of language contacts. For example,
frequent contacts with Spanish-speaking people who are LEP may require
certain types of assistance in Spanish. Less frequent contact with
different language groups may suggest a different and less intensified
solution. If an LEP person accesses a program or service on a daily
basis, a recipient has greater duties than if that same person had
unpredictable or infrequent contact with a recipient's program or
activity. Notwithstanding, recipients should consider whether
appropriate outreach to LEP persons could increase the frequency of
contact with LEP language groups.

1\. Does your organization have a process for surveying, collecting
and/or recording primary language data for individuals that participate
in your programs and activities?

 YES  NO

If no, consider what process would be used for collecting such
information, including: the method of collection and/or recording the
data, the categories that would be used in collection, where the data
would reside, and who could access the data.

2\. To assist in determining the frequency of the contacts or encounters
by respective language groups, you may wish to consider: the prevalent
language group(s), the number of contacts or encounters with a language
group in a week, month or other time period, the type of non-English
assistance provided and by whom, and the person with access to such
data.

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3\. Are the percentages of those LEP groups in the general population
(Section I) fairly consistent with the frequency percentages encountered
by your organization?

 YES  NO

**Section III: Importance**

Once the recipient has assessed, both through an analysis of the
demographics and frequency of contact, the languages to consider with
regard to access, the recipient can then look at the nature and
importance of specific programs, activities, or services.

As a rule of thumb, the more important the activity, information,
service, or program, or the greater the possible consequences of the
contact to the LEP individuals, the more likely language services are
needed. The recipient should determine whether denial or delay of access
to services or information could have serious implications for the LEP
individual. The more important the activity, information, service, or
program, or the greater the possible consequences of the contact to LEP
individuals, the more likely language services are needed. For example,
the requirements for eligibility for a workforce program, or filing a
claim for unemployment insurance or Trade Adjustment Assistance programs
must be effectively communicated. Recipients need to determine whether
denial or delay of access to services or information could have serious
or even life-threatening implications for an LEP individual. Decisions
to make an activity compulsory, such as job training and/or job search
certification in the Unemployment Insurance Program can also serve as
strong evidence of the program's importance.

1\. Do you conduct compulsory activities? For example, do you require
applications, registrations, consent, interviews, or other activities
prior to participation in any of your programs and/or activities, in
order to obtain some benefit, service, or information, or in order to
participate in a higher level program?

 YES  NO

2\. In addition to the above, do you conduct programs or activities that
have serious consequences, either positive or negative, for a person who
participates? For example, some consequences of not having access to
unemployment benefits may potentially include not being able to support
one's self or family in terms of food, shelter, etc.

 YES  NO

3\. Have you determined the impact on actual and potential beneficiaries
of delays in the provision of services or participation in your programs
and/or activities (economic, educational, health, safety, housing,
ability to assert rights, transportation costs, etc.)?

 YES  NO

4\. For those programs or activities with serious consequences, has your
organization translated vital documents into various languages other
than English for LEP customers or beneficiaries, for the purpose of
reducing the negative impact of potential delays in the provision of
services or participation in your programs and/or activities?

 YES  NO

**Section IV: Resources**

Once the recipient has reviewed the demographics, frequency of contact,
and importance of programs, activities, or services, a good
self-assessment will identify the resources (dollars and personnel)
available to ensure the provision of language assistance to LEP persons
participating in the recipient's program and/or activities. The level of
resources and the costs may have an impact on the nature of the language
assistance provided. Smaller recipients with more limited budgets are
not expected to provide the same level of language services as larger
recipients with large budgets. In addition, "reasonable costs" may
become "unreasonable" where the costs substantially exceed the benefits.

Reduction of costs for language services can be accomplished by such
options as the use of technology (such as through the internet,
telephonic language lines, etc.); the sharing of language assistance
materials, and services among and between recipients, advocacy groups,
and Federal grant agencies; and through reasonable business practices.
The recipient should carefully explore the most cost-effective means of
delivering competent and accurate language services before limiting
services due to resource concerns.

1\. Have you identified the resources needed to provide meaningful
access for LEP persons?

 YES  NO

If no, consider the following when identifying the resources needed: the
type of assistance necessary and resources available, the possible
sources of the assistance, the associated costs, and the language groups
assisted.

2\. Is there a staff member in your organization assigned to coordinate
language access activities?

 YES  NO

3\. Have you identified the points of contact where LEP persons interact
with your organization?

 YES  NO

If no, consider the various points where an LEP person may come into
contact with your organization. In such cases, who will assist the
person? How often does it occur and how long might the visit last? How
will the visit be recorded?

4\. Given all of the possible points of contact, is language assistance
available at each of those points?

 YES  NO

5\. By language spoken, how many employees in your organization fluently
speak a language other than English?

6\. What percent of the total employees in your organization are
bilingual and able to competently assist LEP persons in the LEP person's
language?

7\. Do you utilize employees in your organization as interpreters?
(Interpreting is a different skill than being bilingual and able to
communicate monolingually in more than one language. Interpretation
requires particular skills. For more information, see
<http://www.dol.gov/oasam/regs/fedreg/notices/2003013125.pdf>)

 YES  NO

8\. Employees within our organization provide interpreter services
(check one):

Some of the time

Most of the time

Always

Never

9\. What outside sources for interpreter services do you use?

Contract Interpreters

Telephone Services

Community-Based Organizations

Language Banks

Other (please specify)

10\. For what languages (other than English) are outside sources of
language interpreters most commonly used?

11\. Although you should not plan to rely on a LEP person's friends,
family members, or other informal interpreters in order to provide
meaningful access, are there times when you appropriately allow use of
such informal interpreters? (See
<http://www.dol.gov/oasam/regs/fedreg/notices/2003013125.pdf>)

 YES  NO

If yes, under what circumstances?

12\. Are minors used as interpreters? If so, under what circumstances
and how are issues such as competency, appropriateness, confidentiality,
and volunteerism assessed?

 YES  NO

13\. If additional resources are needed to ensure meaningful access,
have you identified the cost of those resources?

 YES  NO

14\. Are there currently any limitations in resources (dollars and/or
personnel) that could impact the provision of language assistance
services?

 YES  NO

15\. If there are currently limitations, have you explored all options
available to you in order to ensure the provision of language assistance
services?

 YES  NO

For example, if there is a significant LEP population that speaks one
language, you may wish to look at the option of hiring staff who are
bilingual, bi-cultural, and knowledgeable in the particular area for
which you provide a service, i.e., healthcare, education, science, etc.
If there is a very small language population, you would not necessarily
need to hire staff to meet that need; instead, you may wish to contract
for that assistance. (See <http://www.dol.gov/oasam/programs/crc> for
more specific help)

16\. What is the total annual funding spent on provision of services in
languages other than English? Consider categorizing the expenses as
those related to: publications, website development and maintenance,
outreach activities, translation activities, language line contractors,
etc.

17\. Does your organization have a written LEP Plan?

 YES  NO 