EqualityCivilRights__Key_Elements_for_an_LEP_Plan.pdf: 15 downloads, before Oct. 1, 2020

Mizell, Melinda

English

eCommons@Cornell

Typical Elements in Limited English Proficiency Plans

DigitalCommons@ILR

Cornell University ILR School 
DigitalCommons@ILR 
Buffalo Commons Centers, Institutes, Programs 
11-2015 
Typical Elements in Limited English Proficiency Plans 
Melinda Mizell 
Follow this and additional works at: https://digitalcommons.ilr.cornell.edu/buffalocommons 
Thank you for downloading an article from DigitalCommons@ILR. 
Support this valuable resource today! 
This Article is brought to you for free and open access by the Centers, Institutes, Programs at 
DigitalCommons@ILR. It has been accepted for inclusion in Buffalo Commons by an authorized administrator of 
DigitalCommons@ILR. For more information, please contact catherwood-dig@cornell.edu. 
If you have a disability and are having trouble accessing information on this website or need materials in an 
alternate format, contact web-accessibility@cornell.edu for assistance. 
Typical Elements in Limited English Proficiency Plans 
This article is available at DigitalCommons@ILR: https://digitalcommons.ilr.cornell.edu/buffalocommons/344 
 237 Main Street, Suite 1200, Buffalo NY 14203 ■  716.852.4191 x117  ■  www.ppgbuffalo.org 
 
 
Typical Elements in Limited English Proficiency Plans 
 
I. Introduction/Purpose 
a. Purpose/Legal Basis 
i. This section outlines the purpose of the policy and the legal basis for 
its existence.  This would include Title VI of the Civil Rights Act and 
Executive Order 13166. 
b. Background 
i. This should include a discussion of demographics of the region, 
including information on its foreign-born population.  Additional 
information about the development of the Limited English Proficiency 
Plan (LEPP) can be included here as well. 
 
 
II. Identifying LEP individuals/Needs Assessment 
This is typically one of the first sections included in an LEPP.  This section 
outlines the initial evaluation process that individual agencies should conduct to 
determine what language services, and to what extent, should be provided by the 
agency.  This section should include who will perform this assessment and 
timelines in which this assessment should be completed by each agency. 
 
a. Four Factor Analysis 
i. The Department of Justice has outlined a four factor analysis that 
agencies should implement to determine the obligations they have in 
offering language accessibility and the appropriate avenue for offering 
those services.  This analysis includes: 
 How many LEP individuals live in the geographic location in 
which the agency provides services? 
 How many LEP individuals come into contact with the 
agency? 
 How important the service is that is provided by the agency? 
 And the cost to the agency of providing that service.   
Each federal department has established an individual guidance for 
implementing this measure.  Direct links to these Federal Registers can 
be accessed at 
http://www.lep.gov/guidance/guidance_Fed_Guidance.html. 
  
2 
Additionally, a sample self-assessment can be accessed at 
http://www.lep.gov/resources/2011_Language_Access_Assessment_a
nd_Planning_Tool.pdf - Appendix B. 
b. Identifying Top Languages 
i. As a part of the initial analysis, information on the demographics or 
top languages spoken within the region’s population should be 
provided in this section.  In doing this analysis, the planners may want 
to use a variety of sources including census data, public school data, 
and refugee resettlement data.  This is information is vital to provide 
within the LEPP.  These languages will provide guidance to individual 
agencies when making decisions about, not only what services should 
be provided, but in what languages should be readily available.  
Routine monitoring of changes in these languages should take place to 
accommodate changes in trends of immigration and resettlement.  
How this monitoring will be conducted and at what time frame should 
be outlined. 
III. Services Offered 
a. Bilingual Staff 
i. Outlines the role of bilingual staff for the delivery of language 
services.  This should include information on preferences and 
incentives of hiring bilingual staff, the integration of providing 
interpreting and translation services into their job descriptions, and to 
what extent language services delivery should be a part of their role 
within the organization.   
b. Oral interpreting 
i. This section should provide general protocols for when oral face-to-
face interpreting is required, when it is appropriate to use alternate 
technologies, and to what extent these services are available.  
Additionally, expectations must be outlined on the use of children, 
family, and friends acting as interpreters. 
c. Translation 
i. This provides information on the availability of translated documents, 
including what types of documents should be translated and into what 
languages. Additionally, this includes information as to what 
documents or notices need to include a language block.   
d. Funding  
i. This outlines funding source for obtaining language services.  
 
 
  
3 
IV. Language Access Procedures 
a.  Identifying LEP individuals 
i. Defines who is considered an LEP individual within the policy.  The 
federal government defines an LEP individual as “Individuals who do 
not speak English as their primary language and who have a limited 
ability to read, speak, write, or understand English” (see 
www.lep.gov). 
b. Protocol for Offering Interpreting Services 
i. Procedures that must be taken when an agency comes into contact with 
an LEP individual.  This includes distinction of procedures between 
telephone, in-person, and other contact.  Additional protocol should be 
outlined for accessing bilingual staff. 
c. Protocol for Translation of Documents 
i. What documents or notices are translated and into what languages they 
are available.  The process of obtaining a translation, including 
timelines for receiving that translated document.   
d. Resources 
i. Manual 
1. This section includes information on the development of a 
resource manual that should be readily available for staff.  This 
includes location of the manual and how to access its contents. 
The contents should include information on bilingual staff that 
work within the agency and how to contact them if needed for 
language services.   Information should be provided on how 
staff may access interpreting and translation services and 
contact information to providers approved as contractors for 
these services.  Additionally, information should be provided 
on who to contact in case an issue arises when dealing or 
providing services to an LEP client.  The manual should also 
include community resources and agencies, and basic cultural 
competency information about the larger foreign language 
populations. 
e. Documentation  
i. How languages will documented for specific clients.  How will this 
information will be tracked and the system to do so, should be 
included as well. 
 
  
4 
 
V. Implementation 
a. Training of Staff 
i. Bilingual staff 
1. What credentials or training would be required of bilingual 
staff in order to offer appropriate language services.  Included 
in this should be an outline of what trainings may be offered by 
the organization and what trainings will be required outside the 
agency (including whether funding may be available to receive 
these outside trainings). 
ii. New Staff 
1. What cultural competency and language access trainings will 
be provided to new staff and who shall conduct those trainings.  
This includes outlining collaborative relationships that exist 
with outside community agencies and the protocols to 
accessing those services.  
iii. Existing Staff 
1. What types of training will be provided (ie: cultural 
competency, working with an interpreter, language services 
education, etc). 
iv. Volunteers 
1. Expectations and procedures regarding the training of 
volunteers that may come in contact with LEP populations 
should be specified here.   
v. Ongoing training 
1. What additional trainings will be conducted and on what basis, 
and, possibly, who is approved to provide those trainings. 
b. Appointing a language services compliance officer within the agency 
i. Many LEPPs require the appointment of a person within the agency to 
handle all issues related to the implementation and ongoing monitoring 
of the plan.  Additionally, each agency should develop unique duties in 
which this person is responsible. Information needs to be provided on 
how this person will be introduced to staff and where that contact 
information can be easily accessed.  
 
 
 
 
 
  
5 
 
VI. Notice to the Public 
This section typical outlines how county agencies make these services known and 
available to the public.  Agencies have a responsibility to inform the public of the 
services available to prevent discrimination based on language.   
a. Signage 
i. What signage is needed to convey the availability of language 
services.  Information on what languages should be included and 
where that information should be placed should be included at the 
discretion of the individual agency.  This includes signage that 
specifically advertises language services. 
b. Outreach materials (brochures, notices, etc) 
i. This defines what education or notice of availability of new services 
needs to be translated.  Additionally, informational brochures on the 
availability of language services within agencies that are translated 
into top languages should be required here.  The scope of this outreach 
should be defined and outline through what mediums the information 
will be delivered (ie: website, television, print, on-site presentations, 
etc). 
VII. Evaluation  
a. Monitoring services offered 
i. This section should include information that addresses the following 
questions: 
1. How will language service delivery be monitored?   
2. What tools or measurements will be used to evaluate those 
services?   
3. What information should be tracked?   
4. How often this information should be reviewed or collected? 
5. Who should be collecting this information? 
b. Quality Assurance of interpreting 
i. This section will outline what credentials are needed to provide 
language services within a given agency.   
c. Complaints 
i. This section should outline how complaints will be processed both by 
the agency and by the client.   
 


https://digitalcommons.ilr.cornell.edu/cgi/viewcontent.cgi?article=1343&amp;context=buffalocommons

Typical Elements in Limited English Proficiency Plans

Abstract

Similar works

Full text

Available Versions

eCommons@Cornell

DigitalCommons@ILR