# Presentation: 104337

## Language Assistance Planning and Self Assessment Tool 

- Analysis Summary

## Background

- September 29, 2006 distributed the Language Assistance and Self-Assessment Planning Tool for Recipients of Federal Financial Assistance
- Requested responses by January 31, 2007
- Received responses from 85 recipients

## Existence of a Written Language Assistance Policy

- 65% of responding recipients have a written policy for the Limited English Proficient (LEP)
- 35% do not have such a policy

**Notes:**
35%(30) of all participants do not have a written policy. This is a high percentage. There are definitely very easy steps with which to improve on this situation.

One area of resource is the Civic Right Center. We can provide guidelines on how to generate such a written policy. In addition, there are 65% who have generated a written policy on the provision of services to LEP individuals. So this conference is an excellent place and time for accessing both of these resources.

## Existence of a Written Language Assistance Policy

- 65%
- Have a Written Policy

- 35% Have NO Written Policy

**Notes:**
Having a written policy is just the starting point. With a written document, it is possible to standardize rules,  procedures and processes. It is a reference point to which the members of the organization can know that they are obliged to provide meaningful access to information and services for Limited English Proficient(LEP) individuals. 

## Distribution of Written Language Assistance Policy

- 73% of responding recipients that have a written language access policy, distributed the written policy
- 27% do not distribute such a policy

**Notes:**
There may be various reasons for not distributing the written policy. Maybe there may not be a schedule or a plan to distribute such a written policy. Again, I will like to reiterate that this conference is a place for networking and exchanging best practices. 
Some questions you can ask your contemporaries is whether they have a written policy and if they do, how do they go about distributing it. Do they do it monthly? Do they use their new employee orientation as their starting point?

How do they move from distributing the written policy to their employees to distributing it to the contractor and the general public?

## Distribution of Written Language Assistance Policy

- 27% Did not distribute
- written policy

- 73% Distribute
- written policy

**Notes:**
We see that out of the 55(65%) which have a written policy, only 73%(40) of them distributed the written policy. This is counterproductive. Today there are more tools to distribute a written policy:
By hand
By mail
By fax
By email
With these means of distribution, distributing it should be easy. Hence 35% of those, who have a written policy, not distributing it is an unacceptable percentage.

## Recipients with a Comprehensive Language Assistance Plan

- 58% of responding recipients have a comprehensive plan
- 42% do not have a comprehensive plan

**Notes:**
36 or 42% not having a comprehensive plan may be a cause for great concern. It still may be possible to meet needs but there may be delays and additional costs. The immigrant population is always increasing and becoming more diverse. The needs will continue to grow and increase in diversity and complexity. The increase in population and diversity will leads to the need for more resources and the need to allocate resources more efficiently.

## Recipients with a Comprehensive Language Assistance Plan

- No comprehensive plan
- 42%

- Have a comprehensive plan
- 58%

**Notes:**
With no comprehensive plan in place, can services be provided efficiently?

We believe that it is extremely difficult without a plan that integrate these different elements. The resources for this year or this quarter may not meet the resources of next year. There may be a need for Portuguese translator and literature this quarter but there may be an influx of immigrants from Cambodia. The education level may be lower. They may use a different alphabet or may not have an alphabet like our. 
How do we switch gears from catering to Portuguese speakers who understand Spanish in some degree and use a similar alphabet to Cambodian whose language and culture is extremely different from the European language and culture? After a year? After a quarter?

## Communication of Language Assistance Policy to Employees

- 16% of responding recipients do not communicate their language access policy to their staff
- 84% of responding recipients do communicate the policy to the staff

## Communication of Language Assistance Policy to Employees

- 16% Do NOT communicate
- policy to staff

- 84% Communicate
- policy to staff

**Notes:**
The starting point for communicating the policy is within the recipient’s organization.

It is comforting to know that 81% of the organizations do communicate to your employees of this obligation to provide meaningful access to services and information for LEP persons.

We look forward to this percentage of 81% being increased to 100% which is highly feasible.

## Advise Contractors of Language Assistance Policy 

- 28% of all responding recipients do not inform contractors of their language assistance policy
- 72% do inform contractors

**Notes:**
What hindrances are faced in providing such information?  Would a written policy be useful in such situation? Can the written policy used for the employees be employed for the subcontractors, as well? Can this be attached along with other informational material to be discussed with subcontractors?

## Advise Contractors of Language Assistance Policy

- 28% Do NOT inform
- contractors of policy

- 72% Inform contractors
- of policy

**Notes:**
28% do not inform their subcontractors of the policies regarding LEP persons. We are getting shortchanged here. 28% are essentially allowing the subcontractors an excuse for not fully fulfilling their contracts if LEP constitute a percentage of the end users of their services.

## Inform customers of the right to free language services

- 72% of responding recipients inform customers  that language services are available at no cost
- 28% do not inform customers

**Notes:**
28% of beneficiaries are not informed that they will be  provided with interpreting services at no cost.  

This is compounding the distribution problem with a problem in communication. If we are using subcontractors, we are putting ourselves in a position where we underutilize services we have already paid for.

## Inform customers of the right to free language services

- Inform customers of the right to free language services

- 72% Of customers informed
- of right to free services

- 28% Of customers NOT
- informed of right to free service

## Ensure sufficient qualifications of bilingual staff

- 53% of responding recipients ensure that bilingual staff is qualified to provide services in another language
- 47% of responding recipients do not ensure that bilingual staff is qualified to provide services in another language

**Notes:**
One of the most basic areas to ensure is that of the personnel. Almost half(47%) of the participants ensure that their bilingual staff are qualified to provide services in another language. 

## Ensure sufficient qualifications of bilingual staff

- 53% Ensure staff is qualified
- to provide language services

- 47% Do NOT ensure staff is qualified
- to provide language services

**Notes:**
We start with evaluating within the organization. The starting point is always communication. With LEP individuals, this would means communicating in another languages.
There is a difference in being able to speak a language from being able to translate or being able to interpret. In addition, there are terminology  specific to certain areas such as the medical or insurance field which the typical layman may not know.

## Developed  a demographic profile of the population served by funded programs

- 87% of responding recipients have developed a demographic profile of the overall population served or likely to be served by US DOL funded programs and activities
- 13% have not developed such a profile

**Notes:**
So it goes without saying that developing a demographic profile is essential to knowing whom you need to serve.
87% having developed such a profile is good. Since we know the importance of this, we want to move a step ahead and ask the question of how we can sketch this profile more accurately and more promptly since we know that changes occur quickly.

## Developed  a demographic profile of the population served by funded programs

|  |
| --- |

- 13% Do NOT develop a demographic profile

- 87% Developed a demographic profile

## Demographic profile developed for each labor market or local area

- In service areas covering multiple labor markets, 79% have developed demographic profiles for each labor market or local area
- 21% did not develop demographic profile for each labor market area

**Notes:**
With the same AP excerpt in mind, we also want to think about demographic profiles that fit each labor market or local area. Consider Detroit in the AP excerpt. Its demographic make up will be drastically changed due to the influx of Iraq refugees and it will be different from the rest of Michigan. If we use an outdated census for Michigan, we would be misled in our planning within Detroit.

## Demographic profile developed for each labor market or local area

- 21% Did NOT develop profile
- for each labor market

- 79% Developed profile
- for each labor market

## Developed a profile of the primary languages spoken by the population served

- 84% of the responding recipients have developed a profile of the primary languages spoken by the population served or likely to be served by their Federally funded programs and activities
- 16% Did not develop a profile of the primary languages spoken by the population served

**Notes:**
Knowing what are the primary languages being spoken enable an organization to allocate resources more accurately. Hence 81% would be better able to allocate their resources such as interpreting services for the appropriate language groups. It will be interesting to know how the other 19% allocate such resources and whether they  have to be making adjustments and how drastic are the adjustments.

## Developed a profile of the primary languages spoken by the population served

- 84% Developed profile by language

- 16% Did NOT develop profile by language

## Process for surveying, collecting and recording primary language data

- 69% of responding recipients have a process for surveying, collecting and recording primary language data for individuals served
- 31% have no process in place for surveying, collecting and recording primary language data

**Notes:**
To determine such frequency, we must first establish a process for surveying, collecting and recording primary language data for individuals that participate in these programs and activities.
Again, we want to consider the possibility of exchanging ideas at this conference of how each state or LWIA has used such a process.

## Process for surveying, collecting and recording primary language data

- 31% Have NO collection process

- 69% Have collection process

## Translate vital documents into languages other than English for LEP customers/beneficiaries

- 78% of responding recipients translated vital documents into languages other than English for LEP customers or beneficiaries
- 22% did not translate vital documents into languages other than English

**Notes:**
For those programs or activities with serious consequences, 78% have 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 provisions of services or participation in your programs and/or activities.

## Translate vital documents into languages other than English for LEP customers/beneficiaries

- 22% Did NOT translate vital documents

- 78% Translated vital documents

## Identified the resources needed to provide meaningful access for LEP persons

- 74% of responding recipients have identified the resources needed to provide meaningful access for LEP persons
- 26% did not identify the resources needed to provide meaningful access for LEP persons

**Notes:**
What do we want to consider when looking at resources needed:
Type of assistance necessary and resources available; 
the possible sources of assistance; 
the associated costs, and 
the language groups assisted.

## Identified the resources needed to provide meaningful access for LEP persons

- 26% Did NOT identify resources needed
- to provide meaningful access for LEP

- 74% Identified resources needed to provide
- meaningful access for LEP

**Notes:**
22 % have not identified the resources needed to provide meaningful access for LEP persons. If this is representative, it is worrisome. This is because when you encounter a resource-deficient situation, the provision of such access would be curtailed or even worse, neglected altogether.

## Staff person designated to coordinate language access activities

- 31% Do NOT have staff coordinator

- 69%  Have staff coordinator

**Notes:**
This is a useful resource to have. It may be a necessity for everyone to have a person only dedicated to coordinating language access activities. It could be part of a staff member’s duties in addition to other responsibilities. This is an evolving area. It is up to management’s decision as to what proportion of a staff time this would take up. It should be assessed regularly, at least on an annual basis as to the proportion.

## Staff person designated to coordinate language access activities

- 69% of responding recipients use at least one staff member assigned to coordinate language access activities
- 31% have no staff member assigned to coordinate language access activities

**Notes:**
It is not easy to describe such a staff member...whether it will be a person who is primarily assigned to LEP services or who has other duties or a contractor. What skills are needed? Only through doing a self assessment which include the demography of the people served and the demands, can we  answer this question?

## Identified the points of contact where LEP persons interact with the organization

- 88%  Identified each point of interaction

- 12% Did NOT identify each point of interaction

**Notes:**
At an agency office, via telephone, via internet? 

Are there signage and posters strategically positioned so as to catch the customer’s eyes easily?

## Identified the points of contact where LEP persons interact with the organization

- 88% of responding recipients identify each point of contact at which LEP persons interact with the organization
- 12% do not identify each point of contact

**Notes:**
The use of each of these may depends on other resources as well.  It will also depends on what level of interaction is needed with the LEP individual. 
Can they read? 
Do they have access to a computer? 

## Provide language assistance at each possible point of contact

- 78% of responding recipients make language assistance available at each point of contact
- 22% do not make language assistance available at each point of contact

**Notes:**
Efficiency of use of language services can be accomplished by such options such as the use of technology (such as through the internet, telephonic language lines); the sharing of language assistance materials, and services among and between recipients, advocacy groups and Federal grant agencies ; and through reasonable business practices.

## Provide language assistance at each possible point of contact

- 22% Do NOT provide language assistance
-  at each point of contact

- 78% Provide language assistance
-  at each point of contact

**Notes:**
Efficiency of use of language services can be accomplished by such options such as the use of technology (such as through the internet, telephonic language lines); the sharing of language assistance materials, and services among and between recipients, advocacy groups and Federal grant agencies ; and through reasonable business practices.

## Utilize employees in the organization as interpreters

- 80% of responding recipients utilize employees within the organization as interpreters
- 20% do not utilize employees within the organization as interpreters

## Utilize employees in the organization as interpreters

- 20% Do NOT utilize staff to interpret

- 80% Utilize staff to interpret

## Utilize customer’s friends or family members as interpreters

- 79% of responding recipients utilize friends or family members of the customer as informal interpreters
- 21% do not utilize family members or  friends to interpret

## Utilize customer’s friends or family members as interpreters

- 21% Do NOT utilize friends & family to interpret

- 79% Utilize friends & family to interpret

**Notes:**
Some of the disadvantages here are obvious. Some are not.
The interpreter may be emotionally involved. There may be technical words which the interpreter may not be familiar with. There may be a conflict of interest.

## Utilize minors as interpreters

- 15% of responding recipients utilize minors as informal interpreters (i.e. customer’s English speaking children)
- 85% do not utilize minors as informal interpreters

## Utilize minors as interpreters

- 15% Utilize minors as interpreters

- 85% Do NOT utilize minors as interpreters

**Notes:**
As a policy, this should not be the case. Minors are usually emotionally fragile. Unfortunately sometimes the minors help the elders not only with interpreting but also with their physical needs.