U.S. General Services Administration

Professional Services and Human Capital Categories (PSHC)

Foreign Language Services Ordering Guide

Prepared by Members of the Language Services

Procurement Committee

August 2016

Updated May 2023
Table of Contents

Background 3

Legal Requirements and Guiding Policy 4

Definitions 8

GSA Description of Language Services 11

Assessing Your Agency’s Language Needs 12

Choosing a Provider 13

Scope of Services 13

Monitor Performance 13

Special Topics 15

Page 2 of 16

Revised May 2023
Background

Approximately 21 million individuals in the United States are considered limited English proficient (LEP)

and the population of LEP individuals continues to grow.

1An individual with limited English proficiency is

a person whose primary language for communication is not English and who has a limited ability to read,

write, speak, or understand English. Language access services, including, but not limited to, oral

interpretation and written translation, are essential to ensuring accurate and effective communication

between LEP persons and non-LEP persons.

Federal agencies are required to provide LEP individuals with meaningful access to federal programs and

activities under Executive Order 13166, “Improving Access to Services for Persons with Limited English

Proficiency.” The order also requires that Federal agencies work to ensure that recipients of Federal

financial assistance provide meaningful access to their LEP applicants and beneficiaries in compliance

with Title VI of the Civil Rights Act of 1964.

2

To ensure effective communication with LEP individuals, all federal agencies must have language

assistance services in place. Most agencies utilize the General Services Administration (GSA) Language

Services Schedule to procure the services needed to overcome language barriers. This ordering guide is

intended to: (1) assist agencies, program staff, and their procurement officers in using the existing GSA

Language Services Schedule to purchase language services and, (2) offer tips and best practices for

procuring high quality language assistance services. Please note that while the Language Services

Schedule includes services for the deaf and hard of hearing, the scope of this ordering guide is limited to

foreign language services such as translations and interpretations.

Legal Requirements and Guiding Policy

Before purchasing language services, agencies should be aware of their legal obligations, internal policy

directives, and regulations aimed at serving LEP members of the public. This section outlines some of

these requirements.

a. Executive Order 13166 – Applicable to all federal agencies

On August 11, 2000, the President signed Executive Order 13166, “Improving Access to Services for

Persons with Limited English Proficiency.” The Executive Order requires that federal agencies: (1) work to

ensure that recipients of federal financial assistance provide meaningful access to their LEP applicants

and beneficiaries; and, (2) ensure that LEP individuals have meaningful access to federally-conducted

programs and activities. Meaningful access is defined as language assistance services that result in

accurate, timely, and effective communication with the LEP individual. To fulfill the mandate that

federally-conducted programs are meaningfully accessible to LEP individuals, the Executive Order

requires federal agencies to examine the services they provide, identify

1U.S. Census Bureau. 2010. 2013 American Community Survey.

2 See, Memorandum from Attorney General Eric Holder to the Heads of Federal Agencies, General Counsels, and

Civil Rights Heads on the Federal Government’s Renewed Commitment to Language Access Obligations under

Executive Order 13166. February 17, 2011 (located at: go.usa.gov/x2MPA).

Page 3 of 16

Revised May 2023
whether LEP individuals need the agencies’ services, and develop and implement a system to provide

appropriate language assistance services to LEP persons.

3

The language access obligations of Executive Order 13166 also apply to programs and activities funded

by the federal government. When a federal agency provides federal financial assistance, it must ensure

that recipients acknowledge and agree that they will comply (and require any sub-grantees, contractors,

successors, transferees, and assignees to comply) with applicable provisions of federal civil rights laws

and policies prohibiting discrimination, including, but not limited to, Title VI of the Civil Rights Act of

1964, which prohibits recipients from discriminating on the basis of race, color, or national origin,

including limited English proficiency (see discussion of Title VI obligations below).

4

I. Agency Language Access Plans

In his 2011 Memorandum, Attorney General Holder directed each federal agency to develop and

implement a system by which LEP persons can meaningfully access the agency's services. The Attorney

General recommitted agencies to the language access obligations of Executive Order 13166 and laid out

three elements of an effective language access strategy.

First, a Language Access Implementation Plan helps management and staff understand their roles and

responsibilities with respect to overcoming language barriers for LEP individuals. The plan is a

management document that outlines how the agency has or will define language assistance tasks, set

deadlines and priorities, assign responsibility, and allocate the resources necessary to come into or

maintain compliance with language access requirements. It describes how the agency will effectuate the

service delivery standards delineated in the policy directives, including the manner by which it will

address the language service and resource needs identified in a self-assessment.

Second, Language Policy Directives set forth standards, operating principles, and guidelines that govern

the delivery of language appropriate services. Policy directives come in different forms, but they institute

requirements on the agency and its staff to ensure meaningful access. Policy directives should be

available to the public so that LEP beneficiaries will understand that in-language assistance is available.

Finally, Language Access Procedures provide the "how to" for staff. They specify for staff the steps to

follow to provide language services, gather data, and deliver services to LEP individuals. Procedures are

often set forth in staff handbooks or other internal guides and websites.

3 To assist Federal agencies in carrying out their language access responsibilities, the U.S. Department of Justice

issued a Policy Guidance Document, “Enforcement of Title VI of the Civil Rights Act of 1964 - National Origin

Discrimination Against Persons With Limited English Proficiency” (LEP Guidance). This LEP Guidance sets forth the

compliance standards that recipients of Federal financial assistance must follow to ensure that their programs and

activities normally provided in English are accessible to LEP persons and thus do not discriminate on the basis of

national origin in violation of Title VI's prohibition against national origin discrimination.

4 Supra, 2011 Holder Memorandum

Page 4 of 16

Revised May 2023
Violation of these plans, policies and procedures may even result in reprimand or dismissal of the staff

member. A recent case, involving the Department of Justice, Executive Office of United States Trustees,

revealed that where a federal official failed to follow an agency’s language access plan, an agency is

within its authority to suspend the official without pay.

5

Each agency and each recipient of federal financial assistance must take reasonable steps to provide

meaningful access to LEP individuals. To assist agencies in determining their language services capacity,

the Department of Justice created a Language Access Assessment and Planning Tool for Federally

Conducted and Federally Assisted Programs. The tool and additional resources for language access

planning are available at http://www.lep.gov/resources/resources.html#LAP.

b. Title VI of the Civil Rights Act of 1964 – Applicable to all federal agencies that

provide federal financial assistance

Title VI, 42 U.S.C. § 2000d et seq., was enacted as part of the landmark Civil Rights Act of 1964. It

prohibits discrimination on the basis of race, color, and national origin in programs and activities

receiving federal financial assistance. As President John F. Kennedy said in his 1963 Civil Rights Address:

Simple justice requires that public funds, to which all taxpayers of all races [colors, and national origins]

contribute, not be spent in any fashion which encourages, entrenches, subsidizes or results in racial

[color or national origin] discrimination.

The Supreme Court decided, in Lau v. Nichols, over three decades ago that a federal fund recipient’s

denial of education to a group of non-English speaking students violated Title VI and its implementing

regulations.

6 Since the Supreme Court’s decision in Lau, other courts have found that the failure by a

recipient to provide meaningful access to LEP persons constitutes national origin discrimination.

7

If a recipient of federal assistance is found to have discriminated and voluntary compliance cannot be

achieved, the federal agency providing the assistance should either initiate fund termination proceedings

or refer the matter to the Department of Justice for appropriate legal action. Aggrieved individuals may

file administrative complaints with the federal agency that provides funds to a recipient, or the

individuals may file suit for appropriate relief in federal court. Title VI itself prohibits intentional

discrimination, however, most funding agencies have regulations implementing Title VI that prohibit

recipient practices that have the effect of discrimination on the basis of race, color, or national origin.

8

5Memorandum and Order, Pereira v. U.S. Department of Justice (May 11, 2016).

6 Lau v. Nichols, 414 U.S. 563, 569 (1974).

7 See, e.g., Sandoval v. Hagan, 197 F.3d 484, 510-11 (11th Cir. 1999) (holding that English-only policy for driver’s

license applications constituted national origin discrimination under Title VI), rev’d on other grounds, 532 U.S. 275

(2001); Almendares v. Palmer, 284 F. Supp. 2d 799, 808 (N.D. Ohio 2003) (holding that allegations of failure to

ensure bilingual services in a food stamp program could constitute a violation of Title VI).

8 The Federal Coordination and Compliance Section maintains an up-to-date list of agency Title VI Regulations.

Page 5 of 16

Revised May 2023
c. Other Statutory and Regulatory Requirements

Agencies should be aware that certain program statutes and executive orders, and their implementing

regulations, reinforce or supplement the language access requirements of Title VI and Executive Order

13166. Below are a few examples of other statutory and regulatory language access requirements. See

Table 1. for a summary of these requirements.

I. ACA Sec. 1557

The Patient Protection and Affordable Care Act, or ACA, overhauls the U.S. health care system. Section

1557 is the nondiscrimination provision of the ACA, and it prohibits discrimination on the basis of race,

color, national origin, sex, age, or disability in certain health programs or activities. The regulations

implementing Section 1557 include a provision effectuating Section 1557’s prohibition of national origin

discrimination in the context of health programs and activities.

9Under these regulations, covered

entities must provide information about communication assistance, and post taglines informing the LEP

public of the availability of language services in the top 15 languages spoken by LEP individuals in the

relevant state or states.

Like Title VI, Section 1557 provides that covered entities must take reasonable steps to provide

meaningful access to individuals with limited English proficiency. The regulations specify that language

services must be provided accurately, in a timely manner, and be free of charge. Accordingly, interpreters

must be qualified as defined in the regulation. Unqualified individuals, like children or friends, are

restricted from interpreting for covered entities. The 1557 regulation builds on the longstanding civil

rights principles under Title VI and reflects principles familiar to federal agencies under Executive Order

13166. To learn more about the final rule implementing Section 1557, please contact the Office for Civil

Rights at HHS.

10

ii. Executive Order 12250

In 1980, President Carter signed Executive Order 12250, which provided for the consistent and effective

implementation of various laws prohibiting discriminatory practices on the basis of race, color, national

origin, sex, disability, or religion in programs and activities receiving federal financial assistance. The

12250 implementing regulation, or Coordination Regulation, enacts additional Title VI language access

requirements that apply to all federal agencies.

Specifically, the Coordination Regulation requires that federal agencies coordinate their Title VI

enforcement efforts under the guidance of the Department of Justice Civil Rights Division Federal

Coordination and Compliance Section.

11 This includes, but is not limited to collecting data on the

participation of LEP communities in federally assisted programs and activities, and asking both agencies

and their recipients to provide in-language outreach and the translation of vital documents.

9 See 45 C.F.R. 92.201, available at www.hhs.gov/sites/default/files/1557%20FS%20LEP%20%28508%29.pdf.

10See 45 C.F.R. 92.

11 See 28 C.F.R. § 42.405 (d) 1-2 (2014)

Page 6 of 16

Revised May 2023
iii. The Stafford Act

Specific to disaster relief and assistance, the Stafford Act nondiscrimination provisions require that the

Administrator of the Federal Emergency Management Agency (FEMA) lead efforts to prevent

discrimination against LEP individuals in emergency management and assistance. The statute directs the

Administrator to identify and take into account population groups with limited English proficiency in

planning for an emergency or major disaster, ensure that information made available to individuals

affected by a major disaster or emergency is made available in formats that can be understood by LEP

individuals, and develop and maintain an informational clearinghouse of model language assistance

programs and best practices for State and local governments in providing services related to a major

disaster or emergency.

12

Table 1. Summary of Different Legal Requirements for Language Access

Statutory and Regulatory Language

Access Requirements:

Specific Language to Language Access:

Executive Order 13166 Requires federal agencies to examine the services

they provide, identify any need for services to

those with limited English proficiency, and develop

and implement a system to provide those services

so LEP persons can have meaningful access to

them. Also requires that federal agencies work to

ensure recipients of federal financial assistance

provide meaningful access to their LEP applicants

and beneficiaries. Meaningful access is defined as

language assistance services that result in

accurate, timely, and effective communication

with the LEP individual.

Title VI Prohibits discrimination on the basis of race,

color, and national origin in programs and

activities receiving federal financial assistance.

Failure by a recipient to provide meaningful

access to LEP persons can constitute national

origin discrimination. See Lau v. Nichols.

Affordable Care Act Section 1557 Covered entities must provide information about

communication assistance. Entities must post

taglines informing the LEP public of the availability

of language services in the top 15 languages

spoken by LEP individuals in the relevant state or

states.

.

12 See 42 U.S.C. § 5196f (2006).

Page 7 of 16

Revised May 2023
Executive Order 12250 Requires that federal agencies coordinate their

Title VI enforcement efforts under the guidance

of the Federal Coordination and Compliance

Section of the Department of Justice Civil Rights

Division.

The Stafford Act Requires the Administrator of FEMA to lead

efforts to prevent discrimination against LEP

individuals in emergency management and

assistance.

Definitions

To assist agencies in better understanding some of the terminology used in the language services

industry, this section provides definitions for some of the most commonly used terms.

a. Interpretation: The act of listening to a communication in one language (source language) and

orally converting it to another language (target language) while retaining the meaning.

i. In-person Interpretation: Where a qualified interpreter, who is present, listens to

communication in one language and orally converts it into another language (either

consecutively or simultaneously) while retaining the meaning.

ii. Telephonic Interpretation: Where a qualified interpreter, who is on the phone, listens to

communication in one language and orally converts it into another language (either

consecutively or simultaneously) while retaining the meaning.

iii. Video Remote Interpreting: Where a qualified interpreter, connected in video by remote

technology, listens to communication in one language and orally converts it into another

language (either consecutively or simultaneously) while retaining the meaning.

iv. Consecutive interpretation: Where a qualified interpreter performs the interpretation in

the pauses after an utterance, and does not speak while others are talking. The

interpreter will usually signal for speakers to start or stop, in order to ensure that all

parties to the interpretation understand. Consecutive interpretation requires

approximately double the amount of time as a conversation without interpreters, and

time should be budgeted accordingly.

v. Simultaneous interpretation: Where a qualified interpreter performs the interpretation

contemporaneously with the speaker whose words are being interpreted. A

simultaneous interpretation occurs without any pauses since the interpreter and speaker

are talking at virtually the same time. Simultaneous interpretation may require the use

of special equipment, such as headsets or interpreter booths.

vi. Escort interpretation: Where a qualified interpreter accompanies a person or delegation

on a visit, tour, meeting, or interview. Escort interpreting is usually performed through

simultaneous or consecutive interpreting.

vii. Community interpretation: A type of interpreting service more often used to facilitate

social service access in language minority communities. Community interpreting is a

Page 8 of 16

Revised May 2023
broad and flexible field that can encompass work in education, health, housing, social

security and other service areas.

viii. Voiceover interpreting: A type of interpretation technique that records the voice of an

interpreter over the original audio track. This method of interpreting is often used in

audiovisual materials such as new reports and movies in languages where subtitling is

not the norm.

b. LEP individuals: Individuals who do not speak English as their primary language and who have a

limited ability to read, write, speak, or understand English. LEP individuals may be competent in

English for certain types of communication (e.g., speaking or understanding), but still LEP for

other purposes (e.g., reading or writing).

c. Meaningful access: Language assistance that results in accurate, timely, and effective

communication with the LEP individual. For LEP individuals, meaningful access denotes access

that is not significantly restricted, delayed, or inferior as compared to programs or activities

provided to English proficient individuals.

13

d. Qualified Interpreter for an individual with limited English proficiency means an interpreter who

via a remote interpreting service or an on-site appearance:

i. Adheres to generally accepted interpreter ethics principles, including client

Confidentiality;

ii. has demonstrated proficiency in speaking and understanding both spoken English and at

least one other spoken language; and

iii. is able to interpret effectively, accurately, and impartially, both receptively and expressly,

to and from such language(s) and English, using any necessary specialized vocabulary,

terminology and phraseology.

e. Qualified Translator means a translator who:

i. Adheres to generally accepted translator ethics principles, including client

confidentiality;

ii. has demonstrated proficiency in writing and understanding both written English and at

least one other written non-English language; and

iii. is able to translate effectively, accurately, and impartially to and from such language(s)

and English, using any necessary specialized vocabulary, terminology and phraseology.

f. Transcription: Rendering of spoken word, audio, or video from a source language into a written

transcript in either the original source language or a new target language

(translation-transcription).

13Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin

Discrimination Affecting Limited English Proficient Persons (LEP Guidance), 67 Fed. Reg. 41,456 (June 18, 2002).

Page 9 of 16

Revised May 2023
g. Translation: The replacement of written text from one source language into an equivalent

written text in the target language.

i. Editing/Double-Checking: A double check is where a second qualified translator reviews

the source document and the original translation to verify the accuracy, completeness

and readability of the final documents. In order to ensure the accuracy of any translation

at least two qualified translators should review it.

ii. Sight Translation: An oral rendering of written text into spoken language by a qualified

linguist, without changing the meaning, based on a visual review of the original text or

document.

iii. Localization: The process of translating and redesigning software products, websites,

marketing communications, or e-learning systems to appear as native in language

products.

iv. Summarization: The process of reducing a document from a source language into an

abstract or outline while retaining the most important points of the original document in

the target language.

h. Vital Documents: A document will be considered vital if it contains information that is critical for

obtaining federal services and/or benefits, or is required by law. Vital documents include, for

example: applications; consent and complaint forms; notices of rights; notices of disciplinary

action; notices advising LEP persons of the availability of free language assistance; prison

rulebooks, commissary request forms, grievance forms, and health request forms; written tests

that do not assess English language competency, but rather competency for a particular license,

job, or skill for which English competency is not required, and letters or notices that require a

response from the beneficiary or client. For instance, if a complaint form is necessary in order to

file a claim with an agency, that complaint form would be vital. Non-vital information includes

documents that are not critical to access such benefits and services. Advertisements of federal

agency tours and copies of testimony presented to Congress that are available for information

purposes would be considered non-vital information.

14

Note about Cultural Nuance: Successful translation and interpretation services achieve meaning and

ease of understanding for the target audience and avoid literal conversions from English to other

languages. As such, it is important that language service providers understand the cultural nuances of

the target language community. These can include cultural awareness of speech and behavior

differences; hierarchy of power and communication barriers to highlight similarities and differences

between the target and home culture; the ability to promote meaningful dialogue regarding cultural

challenges in the workplace; discuss factors that may affect family, personal, and business relationships;

and run interactive simulations that reflect a realistic situation in the business setting.

14Id.

Page 10 of 16

Revised May 2023
GSA Description of Language Services

GSA’s Federal Acquisition Services (FAS) is improving its professional services offerings. As of October 1,

2020, FAS has consolidated its 24 legacy Schedules (including the Professional Services Schedule (PSS))

into the new Multiple Award Schedule (MAS). The available language services and the applicable MAS

SINs are as follows. Note that, due to MAS consolidation, many services that were previously covered

under multiple different PSS SINs are now combined into a single SIN:

a. Translation Services – MAS SIN 541930

Services included under this SIN include the translation of written, electronic, and multi-media material

to and from English and native foreign languages. Materials include, but are not limited to:

● Business

● Legal

● Medical

● Technical

● Documents

● Software

● Website localization for Internet and Intranet

● Video subtitling

● Captioning

● Transcriptions for Title III Monitoring

Client consultation and Project management services include:

● Translation formatting

● Proofreading

● Text adaptation

● Editing

● Graphic design

● Desktop publishing

b. Interpretation Services— MAS SIN 541930

Interpretation Services include the interpretation of oral communication to and from English and native

foreign languages. Interpretation includes, but is not limited to:

● Simultaneous

● Consecutive

● Escort

● Community

● Telephonic

● Voiceovers

Page 11 of 16

Revised May 2023
Interpreter forums may include:

● Meetings

● Conferences

● Seminars

● Litigation

● Briefings

● Trainings

Client consultation and project management services provide for scheduling, assignment, and logistical

coordination of linguist support.

c. Interpretation Services— MAS SIN 541930

Transcription services for Title III Monitoring are included in this SIN. Note: this does not include medical

transcription, which is included in MAS SIN 561410 Editorial, Publishing, and Library Media Services.

d. Summarization Services – MAS SIN 541930

Written summarization services including gisting fit under SIN 541930. Please contact a GSA contracting

officer if more information is needed based on the scope of work and fitting under the proper SIN.

Assessing Your Agency’s Language Needs

Agencies should conduct a survey or assessment of its language needs before procuring language

assistance services. The purpose of this assessment is to gather information on the number and

frequency of interactions that federal employees have with LEP individuals, particularly when those

interactions involve the receipt of a vital program or activity.

An assessment can help an agency determine if it communicates effectively with LEP individuals, and can

inform its language access program planning including identification of an agency’s funding and

procurement needs. The Department of Justice developed a six-step Language Access Assessment and

Planning Tool for Federally Conducted and Federally Assisted Programs to help agencies conduct a self

assessment of their language needs. The tool includes a sample self-assessment questionnaire to help

agencies evaluate its existing language services and strategize on improving its service delivery to LEP

individuals.

Choosing a Provider

When choosing a language services provider, the purchasing authority should use certain factors to rank

and evaluate providers. Some of these factors are commonplace in procurement (e.g., past

performance), but other factors are more specific to the language services industry (e.g., depth and pool

of linguists). Depending on your requirements, some of these factors may have varying or equal weight.

15 Please note that “gisting” is not an appropriate substitute for interpretation, and may result in significant

additional, potentially detrimental, communication barriers.

Page 12 of 16

Revised May 2023
a. Qualifications: One purpose of this factor is to establish minimum standards for contract

linguists and contract program staff supporting your requirement. Years of experience,

education, training (ongoing), and certifications fall under this factor. Another purpose of this

factor is to determine if a provider possesses the ability to respond effectively to your

requirement. The availability (how many linguists do they have & how fast can they assist?) and

depth (do they even support the language & can they recruit?) of the linguist pool are critical to

assess.

b. Company History and Past Performance: Although a standard evaluation factor in procurement,

the language services industry is somewhat unique in that much of the work is completed

through freelance linguists. This creates overlap between providers. Purchasing authorities

should be thorough in checking subcontractors, the Contractor Performance Assessment

Reporting System (CPARs), OIG reports, and current contract/program managers when reviewing

this factor. CPARs are especially useful for checking a provider’s past performance.

c. Industry Involvement: The purpose of this factor is to determine if a provider is language

centric. This refers to a provider that is dedicated to providing language services, as opposed to a

provider that picked this up as something on the side for extra revenue. Purchasing authorities

are better positioned to select providers who are dedicated to the language services industry.

Providers who are language centric are closely attuned with the language community and local

LEP populations. This proximity enables them to leverage technology, monitor trends, and

engage key stakeholders.

d. Testing: The purpose of this factor is to leverage the industry’s ability to determine a linguist’s

skill set when the government does not have internal resources to do so. A good provider should

test all skill sets and determine level of proficiency. A great provider will do periodic retests to

ensure those skills remain up to speed.

e. Questions to Ask When Selecting a Provider: Common concerns cited with language services

and contracting revolve around three areas: (1) quality, (2) delivery, and (3) administration. One

way to alleviate these concerns is to ask the provider specific questions. Sample questions are

available here.

Scope of Services

In order for agencies to obtain interpretation and translation services, a statement of work (SOW) needs

to be created. An SOW is a written agreement that specifies the end result sought by agencies, along

with a detailed description of the resources required to finish the job. The SOW should include, but not

be limited to, language requirements, format for receipt of documents, quality controls,

interpreter/translator qualifications, and administrative requirements. Sample language service SOWs

are posted in the Statement of Work Library on GSA’s Acquisition Gateway.

Monitoring Performance

When choosing a language services provider, the purchasing authority should inquire about the

provider’s quality assurance practices and quality control standards. Performance monitoring practices

and measures should also be clearly articulated in the contract.

Page 13 of 16

Revised May 2023
a. Quality Assurance

A language service provider should be willing to guarantee the quality of the foreign language services it

delivers. This will require the language service provider to share their process for training linguists and

providing services. Agencies should be mindful that language services often fail when translations and

interpretations are accurate word for word, but do not properly convey the true meaning of the

communication.

Like any other contract-based relationship, agencies should assign liability and specify a dispute

resolution process in the contract.

b. Quality Control Standards

Additionally, providers should be able to describe their internal quality control procedures, such as

screening of potential interpreters or translators, frequency and types of training programs offered after

hire, and quality control/monitoring process. These quality control measures should be detailed in the

contract to ensure that the services are completed in accordance with acceptable principles of internal

control, and meet specified, acceptable levels of quality. The Department of Justice (DOJ) recommends

that providers utilize a Quality Control System and provide a written copy of the plan and any

subsequent revisions to the Ordering Official.

An example of an acceptable Quality Control Plan from DOJ contains at a minimum:

✔ A plan to ensure translation accuracy by using multiple translators to check each project for accuracy

(e.g., every translation has been viewed and approved by at least two qualified translators before being

returned to the Government);

✔ A plan to use and maintain the Government’s glossary, word bank, or index of commonly used terms;

✔ A method of identifying all translators who independently approve of each translation;

✔ A method of addressing poor language assistance services including, but not limited to: inaccurate

translation, untimely service, misplacing or mishandling Government documents; and,

✔ A plan to handle unintelligible information.

Special Topics

a. Service Contract Act (SCA)

The GSA MAS contract incorporates conformed wage determinations for Foreign Language Translators

(Wage Determination 1987-0989) specific to language services on Schedule. Per the applicable contract

clauses, contractors must comply with the base rate and fringe benefit rate requirements of the

prevailing rate SCA Wage Determination Revision Number currently incorporated into the GSA Schedule

contract. No prevailing rate wage determination may be incorporated into a task order as the order then

may conflict with the Schedule terms and conditions. If you have questions regarding the applicability of

Page 14 of 16

Revised May 2023
the Service Contract Act, please contact the GSA Contracting Officer assigned to your task order

contractor.

b. Web and Computer-Based Translation Tools

There are many new and emerging web- and computer-based tools that can be used to help with the

translation process. When used appropriately, these programs can help reduce costs and decrease the

amount of time needed to complete a translation; however, agencies should be mindful of the purpose

and limitations of each.

i. Machine Translations

Machine translations are software or online applications that automatically translate written material

from one language to another without the involvement of a human translator or reviewer. Machine

translations can be a helpful tool; the translations produced, however, are often less accurate and

reliable than the translations provided by qualified human translators. Since machine translations often

translate word for word, they may fail to account for slang, nuance, colloquialisms and terms of art.

Additionally, because languages may differ in vocabulary, alphabet, and writing style, machine

translation often fails to capture not only the meaning of the content, but also the form. It is not

recommended and may be a breach of an agency’s language access plan to use machine translation to

translate vital documents, without the review and double check of a qualified translator. To learn more

about the advantages and disadvantages of machine translations, please read this DigitalGov blog post.

ii. Computer-Aided Translation

Computer-Aided Translation (also known as Computer-Assisted Translation or CAT) is also a software

based translation tool; however, it serves a different purpose than machine translation. CAT tools assist

the translator by providing translations for phrases and sentences that the linguist has previously

translated. This method allows the linguist to increase productivity while maintaining accuracy

throughout the document.

iii. Translation Memory

Translation memory (TM) is another tool that can help enable higher translation productivity for human

translators. TM is a database that captures a human translator’s previous translation and applies it for

future use. When used properly, TM can help reduce costs, provide greater translation consistency, and

help human translators complete translation projects in a shorter amount of time.

c. Word Banks and Glossaries

Some agencies have developed in-house word banks and glossaries as a tool for creating consistent

translations for key terms. A word bank or glossary is a list of approved, standardized terms in the source

language that are relevant to your agency. These tools allow agencies to maintain ownership over

translated terms that have been validated for quality and can be used on a consistent basis. Word banks

and glossaries are also useful for agencies to include with their translation request to providers to save

time and money. Agencies can also work with providers to develop word banks and glossaries for the

agency. Developing these tools helps speed up the translation process, therefore reducing the time and

costs associated with the review and validation cycles.

Page 15 of 16

Revised May 2023
d. Utilizing Multilingual Staff

Many federal agencies employ staff members who are able to speak, read, write and understand

non-English language(s). Before utilizing these staff to fulfill certain language service needs, there are a

number of factors to take into consideration. How does a federal agency ensure that its staff member is

fluent in a non-English language? Does a multilingual employee obtain any benefits (such as pay

differential) for using his or her language skill on the job? Are workload adjustments necessary if a

federal employee’s language skill is in high demand? At a minimum, federal agencies should be wary to

accept at face value an employee’s self identification of fluency in a non-English language. Third party

assessment of a multilingual employee’s linguistic skill, preferably by a professional linguist, is one

acceptable method for assessing the fluency of multilingual workers. Vendors can be useful for providing

assessments of multilingual employee language skill if the federal agency does not have the in-house

capacity and expertise to do so. Agencies should also consider quality standards, pay differentials, and

workload adjustments in determining the impact of utilizing multilingual employees to fulfill the agency’s

language service needs.

e. Community Partnerships

Organizations that have significant contact with LEP persons, such as schools, religious organizations,

community groups, and groups working with new immigrants can be very helpful in linking LEP persons

to an agency’s programs and its language assistance services. Community based organizations provide

important input into the language access planning process and can often assist in identifying populations

for whom outreach is needed and who would benefit from the agency’s programs and activities were

language services to be provided. Community based organizations may also be useful in recommending

which outreach materials the agency should translate. As documents are translated, community-based

organizations may be able to help consider whether the documents are written at an appropriate level

for the audience. Community-based organizations may also provide valuable feedback to the agency to

help the agency determine whether its language assistance services are effective in overcoming language

barriers for LEP persons.

It is not recommended, however, to rely on a community-based organization to provide your agency with

interpreting or translation assistance. The receipt of community-provided interpreting or translation

services without a compensation agreement or MOU may constitute a “gift” and trigger an ethnical

violation. If you are unsure about how your agency should manage community partnerships in this

context, please speak with your ethics officer.

Page 16 of 16

Revised May 2023