Policy/Guide on providing meaningful access to programs for those with limited English proficiency
It is Home Forward policy to take reasonable steps to ensure meaningful access to Home Forward programs and activities by limited English proficient (LEP) persons, taking into account the proportion of LEP persons in the eligible service population, the frequency with which LEP individuals come in contact with the program, the nature and importance of the service provided by the program, and the available resources.
In all housing programs it provides, Home Forward complies with applicable federal and Oregon state housing legislation, including, without limitation:
Title VI of Civil Rights Act of 1964 and the implementing regulations at 24 CFR part 1, ‘‘Nondiscrimination in Federally Assisted Programs of the Department of Housing and Urban Development—Effectuation of Title VI of the Civil Rights Act of 1964’’; Executive Order 13166.
In addition, Home Forward complies with the related rules, regulations and procedures prescribed under the above-mentioned federal and state law.
For the purposes of this plan, Home Forward defines a “program” as follows:
1. Section 8 program
2. Shelter Plus Care program
3. Real Estate Operations
Persons who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English can be a LEP person.
Home Forward shall take reasonable steps to identify LEP persons served or encountered using the following methods:
- Using the Census Bureau “I speak” cards to invite LEP persons to identify their language needs to staff; these cards will be available at all Home Forward offices and application locations.
- Posting notices in all Home Forward offices and application sites listing commonly encountered languages and notifying LEP persons of available language assistance;
Requesting applicants, residents, and participants to list their primary language and need for interpreter on applications and eligibility statements; and
Tracking the LEP information electronically.
Types of Language Services Available
Home Forward shall take reasonable steps to provide oral and written language services as described in this section. In determining what language services should be provided, Home Forward shall consider the following factors:
A. The number or Proportion of LEP Persons Served or Encountered in the Eligible Service Population
Home Forward shall examine its prior experiences with LEP encounters to determine the breadth and scope of language services needed. Home Forward shall also consult other data to refine or validate its prior experience, including the latest census data for the area served.
B. The Frequency With Which LEP Individuals Come Into Contact With the Program
Home Forward shall take reasonable steps to assess, as accurately as possible, the frequency of contact with LEP persons from different language groups. The more frequent the contact with a particular language group, the more likely that enhanced language services in that language are needed. Less frequent contact with different language groups may suggest a different and less intensified solution.
C. The Nature and Importance of the Program, Activity, or Service provided by the Program
The more important the activity, information, service, or program, or the greater the possible consequences of the contact to the LEP persons, the more likely language services may be needed.
D. The Resources Available to Home Forward and Costs
While it is Home Forward’s policy to take reasonable steps to provide meaningful access to Home Forward programs and activities by LEP persons, the availability of resources may limit the provision of language services in some instances. “Reasonable steps” may cease to be reasonable where the costs imposed substantially exceed the benefits. Home Forward shall explore the most cost- effective means of delivering competent and accurate language services before limiting services due to resource concerns.
Home Forward shall use contract interpreters and bilingual Home Forward staff to provide the services. Where LEP persons so desire, they can use, at their own expense, an adult interpreter of their own choosing (whether a professional interpreter, family member, or friend) in place of or as a supplement to the free language services offered by Home Forward. Home Forward may, at its discretion, choose to provide their own Interpreter in addition to the one used by the family.
Home Forward shall take reasonable steps to ensure competency of the language service provider. When providing oral language assistance, Home Forward shall use the following general criteria to ensure effective communication with LEP persons:
Demonstrated proficiency in and ability to communicate information accurately in both English and in the other language and identify and employ the appropriate mode of interpreting;
Knowledge in both languages of any specialized terms or concepts specific to Home Forward’s program or activity and of any particular vocabulary and phraseology used by the LEP person;
Understanding of and following confidentiality and impartiality rules;
Awareness of “regionalisms” used by the LEP person;
Understanding of and adherence to their role as interpreters without
deviating into a role as counselor, legal advisor, or other roles.
When interpretation is needed and is reasonable, it shall be provided in a timely manner so as to avoid the effective denial of a benefit or service. Where access to or exercise of a benefit or service is not effectively precluded by a reasonable delay, the language assistance may be reasonably delayed.
Home Forward shall take reasonable steps to provide written translations of vital documents that list program rules and instructions for each eligible LEP language group that constitutes five percent or 1,000 persons, whichever is less, of program applicants/participants/residents. Whether or not a document (or information it solicits) is vital may depend upon the importance of the program, information, encounter, or service involved, and the consequence to the LEP person if the information in question is not provided accurately or in a timely manner. For example, applications for certain recreational activities would not generally be considered vital documents, whereas applications for housing could be considered vital.
All documents that require action from an applicant or participant shall include a statement in the languages of eligible groups reading “Important information about your housing! If you need assistance, please contact us immediately.” Home Forward shall take reasonable steps to provide oral interpretation of other documents, if needed.
For all documents available in the languages of eligible groups, the English version of the documents shall include a statement on the bottom in the languages of eligible groups reading “This form is available in (language) upon request.”
For LEP language groups that constitute less than five percent or 1000 persons of program applicants, participants or residents, Home Forward will not translate written materials, but shall take reasonable steps to provide oral interpretation of the written materials upon request.
As with oral interpreters, Home Forward will take reasonable steps to ensure competency of translators of written documents. Where legal or other vital documents are involved, Home Forward shall make a reasonable effort to use certified translators.
When calls are received by an LEP applicant, participant or resident, Home Forward staff will make every effort to determine the language being spoken by the caller. Calls will be forwarded to Home Forward staff who speak the same language as the caller for assistance. If Home Forward staff are not available at the time of the call, the caller will be requested to call back when an interpreter can be available. An interpreter will be secured within a reasonable time frame.
When an LEP applicant, participant or resident comes to a Home Forward office, Home Forward staff will make every effort to determine the language being spoken by the caller by using the “I Speak” cards. If Home Forward staff who speak the language are available to assist the applicant, participant or resident, they will do so, either in person or via telephone. If Home Forward staff are not available at the time of the visit, the person will be requested to come back when an interpreter can be available. An interpreter will be secured within a reasonable time frame.
Correspondence received in languages other than English will be translated by Home Forward staff who speak the language, where available, or by Home Forward’s contracted translation agency. Responses will be translated into the same language as the letter that was received.
Home Forward will ensure that staff knows the obligation to provide meaningful access to information and services to LEP persons. Home Forward will provide training to ensure that:
- Staff are competent on LEP policies and procedures; and
- Staff having contact with the public are trained to work effectively with interpreters.
The training will be included as a part of departmental orientation for new employees.
Staff will be provided with listing of forms available in languages other than English and with a list of bilingual Home Forward staff.
Home Forward shall provide a notice to LEP persons of the availability of free language assistance that ensures meaningful access to Home Forward’s programs and services. Examples of notification may include:
Posting signs in common areas, offices, and anywhere applications are taken. The signs shall be translated into the most common languages encountered;
Stating in outreach documents that language services are available. These statements shall be translated into the most common languages encountered;
Working with grassroots and faith-based community organizations and other stakeholders to inform LEP persons of Home Forward’s services, including the availability of language assistance services;
Home Forward will monitor the implementation of the LEP plan on an ongoing basis to determine whether new documents, programs, services, and activities need to be made accessible for LEP persons. In addition, Home Forward will review its LEP plan annually to evaluate the following information:
Proportion of LEP persons in the eligible service population;
Frequency of encounters with LEP language groups;
Nature and importance of activities to LEP persons;
Availability of resources;
Whether existing language assistance meets the needs of LEP persons;
Whether staff knows and understands LEP plan and its implementation.
Addendum to Plan
As of February 1, 2012, the following information applies to Home Forward’s programs.
|Section 8||Shelter Plus Care||Real Estate Operations|
|Languages Exceeding Five Percent of Population or 1000 Persons||Russian||None||Spanish|
|Languages Applications Currently Translated Into||Russian, Vietnamese, Spanish||None||Russian, Vietnamese, Spanish|
|Languages Forms Currently Translated Into||Russian, Vietnamese, Spanish||None||Russian, Vietnamese, Spanish|
|Use “I Speak Cards”||Yes||Yes||Yes|
|Interpreter Signs Posted||Yes||Yes||Yes|
|Staff Interpreters Available||Russian, Vietnamese, Spanish, Arabic, Mien, Thai, Laotion||Vietnamese, Russian, Estonian, Finnish, Serbian, Spanish, Bosnian||Spanish, Vietnamese, Arabic, Urdu, Somali, Tigrinian, Farsi|
|Protocol in Place for LEP Callers||Yes||Yes||Yes|
|Protocol in Place for LEP Visitors||Yes||Yes||Yes|
|Staff Training on Working with Interpreters||Yes||Yes||Yes|