Under Title VI of the Civil Rights Act of 1964, state, local, or regional entities that receive federal funding to provide programs and services may not discriminate based on race, color, or national origin. Executive Order 13166 extends the language access requirements of Title VI to federal agencies that provide programs and services themselves and specifically addresses persons who, as a result of their national origin, are LEP persons. While the Executive Order does not prescribe specific approaches to language access services, it does require federal agencies to prepare plans (referred to as LEP plans) outlining the steps they will take to ensure that eligible LEP persons can access their programs and activities. According to DOJ, these LEP plans are important because they outline the steps agencies will take to ensure that eligible LEP persons can access federal programs and activities. Federal agencies that provide financial assistance to state, local, or regional programs and services are also required to develop guidance (referred to as recipient guidance) that clarifies the funding recipients’ obligations under Title VI. Rather than express uniform rules of compliance, DOJ’s guidance incorporates “reasonableness” as its guiding principle by suggesting agencies assess their programs, services, or activities using four factors: (1) the number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient; (2) the frequency with which LEP persons come in contact with the program; (3) the nature and importance to people’s lives of the program, activity, or service provided by the recipient; and (4) the resources available to the recipient and the costs of language access services. By instructing agencies to use this four-factor analysis, DOJ’s guidance intends to create a balance between ensuring meaningful access to critical services for LEP persons and not imposing undue burdens on federal agencies or the small businesses, local governments, or nonprofits that may be receiving federal assistance. The Executive Order required agencies to develop and implement their LEP plans by December 11, 2000. Agencies were required to send copies of their LEP plans to the Coordination and Review Section (COR) of DOJ’s Civil Rights Division, which is responsible for serving as a central repository for agencies’ plans. Additionally, COR is responsible for providing technical assistance to federal agencies in developing LEP plans and recipient guidance. Agencies’ recipient guidance was to be submitted to DOJ for review and approval by December 11, 2000. Following DOJ’s approval, each agency was required to publish its recipient guidance in the Federal Register for public comment. Agencies also placed their recipient guidance on LEP.gov, a Web site created by the Federal Interagency Working Group on LEP formed by DOJ in 2002 to share information on efforts to implement the Executive Order. COR maintains the Web site. As of December 1, 2009, 22 federal departments and independent agencies, including 13 of the 16 executive-level departments, had posted completed guidance for funding recipients on LEP.gov. Of these cabinet-level departments, recipient guidance for the Department of Homeland Security (DHS), Department of Defense, and Department of Agriculture are listed as “pending.” Table 1 lists the agencies that have posted their recipient guidance. The number of federal agencies that still must complete recipient guidance or LEP plans could not be determined. The Executive Order does not assign DOJ the responsibility for ensuring agencies complete recipient guidance or LEP plans. Rather, under the Executive Order, executive branch agencies are responsible for determining the need to develop recipient guidance based on whether they provide financial assistance to entities that provide federal services to LEP populations. Likewise, agencies are responsible for determining if they must draft LEP plans by assessing whether they have frequent or significant contact with LEP persons. If an agency determines that it is not required to draft recipient guidance, an LEP plan, or both, the agency is not required to report that determination to DOJ. DOJ has, however, provided technical assistance in many of these determinations and issued numerous reminders to agencies regarding their responsibilities under the Executive Order. For example, on November 12, 2002, the Civil Rights Division issued a memorandum to heads of federal agencies, general counsels, and civil rights directors. Section II of that memorandum asks that each federal agency draft or update LEP plans and urged each agency to place a copy of that plan on its Web site and provide COR with the link so that it could be placed on LEP.gov. Other DOJ letters, speeches, and memoranda have encouraged agencies to publish recipient guidance and to issue or update LEP plans. Although the Executive Order requires agencies’ recipient guidance to be placed in the Federal Register for public comment, there is no similar requirement that agencies make their LEP plans publicly available. Rather, DOJ officials stated that, while it has encouraged agencies to post LEP plans and provide links to those plans on LEP.gov, agencies are given the discretion to make their LEP plans public. Of the 58 agencies that had submitted LEP plans to DOJ as of December 2009, 17 agencies have posted their LEP plans on LEP.gov, these are listed in table 2. Our prior work has noted that high-performing organizations focus on the needs of their external stakeholders. Additionally, on December 8, 2009, OMB issued a memo directing agency heads to promote transparency and accountability by providing the public timely access to information on the activities of federal agencies. As such, publicly available LEP plans could help ensure that federal agencies appropriately focus on the needs of LEP communities by enhancing the transparency of agencies’ efforts and allowing for stakeholder scrutiny. Stakeholder review of LEP plans is especially important given the consequences that may occur if LEP communities do not have the appropriate level of access to federal programs and activities. Of our three selected agencies, only IRS has posted its completed recipient guidance. FEMA and SBA have their recipient guidance listed as “pending.” In regard to LEP plans, only IRS has issued an LEP plan, while FEMA and SBA have not. The elements of an effective LEP plan, which involve agency commitment, a comprehensive needs assessment, systematic provision of services, and ongoing monitoring are included in DOJ’s guidance. We used these elements as criteria to assess the selected agencies’ progress in implementing aspects of the Executive Order. As shown in figure 1, IRS has addressed all the elements of an effective LEP Plan while FEMA has addressed half the elements, and SBA has met one element. Collaboration among agencies to improve LEP access through planning and providing language access services is ongoing, but could be enhanced. Our prior work has found that by collaborating on crosscutting issues, federal agencies are able to deliver results more efficiently than when acting alone. As part of that effort, we have identified practices that agencies can employ to improve their collaboration. Of these practices, we found the following four practices applicable to agencies’ efforts to improve language access services: Define and articulate a common outcome through identifying a compelling rationale for agencies to collaborate; Establish mutually reinforcing or joint strategies by aligning agencies’ activities, core processes, and resources to accomplish the common outcome; Agree on roles and responsibilities, including how the collaborative effort will be led, clarifying who will do what, organizing their joint and individual efforts, and facilitating decision making; and Identify and address needs by leveraging each others’ resources, thus obtaining additional benefits that would not be available if agencies were working separately. Our work found that these collaboration practices are employed by the Federal Interagency Working Group on LEP, a network of federal agencies established in 2002 by DOJ to help foster governmentwide collaboration for serving LEP communities. The working group’s invitation list includes 46 different federal agencies. DOJ estimates that approximately 24 federal agencies participate actively. The group includes the three selected agencies, several cabinet level departments, such as the Department of Health and Human Services, and several smaller agencies, such as the National Labor Relations Board. The group’s mission is to build awareness of the needs and methods for ensuring that LEP persons have meaningful access to federal and federally funded programs and activities. The working group meets approximately twice a year to discuss topics such as language access services in emergency preparedness, promising practices in a variety of contexts, enforcement, and other cross-cutting language access issues. The working group also consists of committees that meet on a more frequent basis to work on various implementation issues. The working group’s Federally Conducted Committee, for example, developed a guide of suggested practices for implementing language access services based on a survey it administered to federal agencies. In addition, the working group convenes larger conferences covering a broader range of issues, such as stakeholder partnerships, dealing with limited budgetary resources, and leveraging technology. COR coordinates these meetings, committees, and conferences. The working group and its committees have sought to improve access for LEP populations by promoting collaboration among federal agencies and state and local government entities. These efforts include sharing information through the production and distribution of informational brochures and videos as well as surveying federal agencies about their initiatives to improve access for LEP persons. Additionally, the working group has sought to increase understanding and dissemination of language data from the U.S. Census Bureau and to strengthen enforcement efforts. According to DOJ officials, the working group reports that their efforts have improved inter-agency understanding of LEP issues, and in some cases, have helped to keep the implementation of the Executive Order and language access services a priority within agencies. The working group’s Web site, www.LEP.gov, which is maintained by COR, shares the information it has collected and the practices it has developed. The Web site includes information on Executive Order 13166, a list of links to agency recipient guidance, as well as some of the published LEP plans that agencies have sent to DOJ’s Civil Rights Division.