HomeMy WebLinkAboutAgenda - 06-16-20; 8-i - Update to Orange County Limited English Proficiency Policy (“Orange County “Language Access Plan”)
ORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date:June 16, 2020
Action Agenda
Item No. 8-i
SUBJECT: Update to Orange County Limited English Proficiency Policy (“Orange County
“Language Access Policy”)
DEPARTMENT: Human Rights and Relations
ATTACHMENT(S):
1. Language Access Policy
2. Limited English Proficiency Policy
(Approved December 11, 2001)
INFORMATION CONTACT:
Annette Moore, Human Rights and
Relations, (919) 245-2317
PURPOSE: To approve an update to Orange County’s Limited English Proficiency Policy
(“Language Access Policy”).
BACKGROUND: On December 11, 2001, the Orange County Board of Commissioners adopted
one of the first Limited English Proficiency policies in the Country. The Policy contained not only
language assistance standards and principles for providing meaningful access to Orange County
services, programs and activities for limited English Proficiency (“LEP”) persons, but also an
Implementing Plan with a “tool box” of services departments could use to address the needs of
the LEP community. Since 2001, neither the Policy nor the Plan been updated. In 2011, the U.S.
Department of Justice issued a “Language Access Assessment and Planning Tool for Federally
Conducted and Federally Assisted Programs.”
Staff is recommending the Board update the Policy for two reasons: (1) to comply with the
Department of Justice Guidance; and (2) review and assess of the County’s language access
program. Included in an assessment of the program will be a “community assessment” to
determine if the tools the County is using are effective and providing “meaningful access” to the
LEP community. If the answer is “no,” staff intends to ask stakeholders what is needed to provide
“meaningful access.” Staff also wants to test the public’s knowledge that the services are
available to the community.
To do this, staff proposes to divide the current LEP Policy into two parts: (1) A Language Access
Policy; and (2) Language Access Plan. The Policy will establish the standards, operating
principles, and guidelines that govern the delivery of language appropriate services. The Policy
directives will require Orange County Government and its staff to ensure meaningful access to its
services, programs and activities to the LEP community. The Language Access Plan will be the
management document outlining how Departments define tasks, sets deadlines and priorities,
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assign responsibility, and allocate the resources necessary to come into or maintain compliance
with language access requirements. It will also describe how departments will meet the service
delivery standards. The Policy is approved by the Board and the Plan would be under the
authority of the County Manager.
The attached Policy is consisted with this concept. If approved, staff will conduct a community
assessment of the County’s language access services over the summer. Based on findings, staff
will develop an Implementing Plan that is consistent with the Department of Justice Guidance for
County Manager review.
FINANCIAL IMPACT: There is no financial impact associated with this item.
SOCIAL JUSTICE IMPACT: The following Orange County Social Justice Goals are applicable
to this item:
GOAL: FOSTER A COMMUNITY CULTURE THAT REJECTS OPPRESSION AND
INEQUITY
The fair treatment and meaningful involvement of all people regardless of race or color;
religious or philosophical beliefs; sex, gender or sexual orientation; national origin or ethnic
background; age; military service; disability; and familial, residential or economic status.
GOAL: ENSURE ECONOMIC SELF-SUFFICIENCY
The creation and preservation of infrastructure, policies, programs and funding necessary
for residents to provide shelter, food, clothing and medical care for themselves and their
dependents.
GOAL: CREATE A SAFE COMMUNITY
The reduction of risks from vehicle/traffic accidents, childhood and senior injuries, gang
activity, substance abuse and domestic violence.
ENVIRONMENTAL IMPACT: There is no Orange County Environmental Responsibility Goal
impact associated with this item
RECOMMENDATION(S): The Manager recommends that the Board approve the Update to the
Limited English Proficiency Policy and change the name of the Policy to the Language Access
Policy.
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Attachment 1
Orange County Language Access Policy
I. Policy Statement
It is the policy of Orange County to provide timely meaningful access for Limited English
Proficiency (“LEP”) persons to all Orange County government services, programs and activities.
All language assistance services are free to all LEP individuals who requests language assistance
services.
II. Purpose and Authority:
The purpose of this policy is to establish effective guidelines, consistent with Title VI of the Civil
Rights Act of 1964 and Executive Order 13166, for Orange County employees to follow when
providing services to, or interacting with, individuals who have limited English proficiency (“LEP”).
Following this Policy is essential to the success of our mission to provide meaningful access to
the LEP community to all Orange County services, programs and activities.
III. Staff Compliance.
Orange County personnel shall provide free language assistance services to LEP individuals whom
they encounter or whenever an LEP person requests language assistance services. Each County
Department Director is responsible to ensure their respective departments have a Language
Access Plan, LEP persons have access to the services their department provides, and to ensuring
department staff receives training on providing language access services to the LEP community.
IV. Definitions.
A. Bi‐lingual staff – A staff person employed by Orange County who has demonstrated
proficiency in English and reading, writing, speaking, or understanding at least one other
language as authorized by his or her department.
B. 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 same meaning.
C. Language Assistance Services – Oral and written language services needed to assist LEP
individuals to communicate effectively with staff, and to provide LEP individuals with
meaningful access to, and an equal opportunity to participate fully in, the services,
activities, or other programs administered by the Department.
D. Limited English Proficient (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 be LEP for other purposes (e.g., reading or
writing).
E. Meaningful Access – Language assistance that results in accurate, timely, and effective
communication at no cost to the LEP individual.
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F. Primary Language – An individual’s primary language is the language in which an
individual most effectively communicates.
G. Program or Activity – The term “program or activity” and the term “program” mean all of
the operations of the Department.
H. Qualified Translator or Interpreter – An in‐house or contracted translator or interpreter
who has demonstrated his or her competence to interpret or translate through testing by
the Department of Human Rights and Relations, Certification by a qualified entity, or is
authorized to do so by contract with the Department and if a County employee approved
by his or her department.
I. Sight Translation – Oral rendering of written text into spoken language by an interpreter
without change in meaning based on a visual review of the original text or document.
J. Translation – The replacement of written text from one language (source language) into
an equivalent written text in another language (target language).
K. Vital Document – Paper or electronic written material that contains information that is
critical for accessing a component’s program or activities, or is required by law.
V. Language Assistance Measures.
Ensuring the quality and accuracy of language assistance services provided by each Department
is critical to providing LEP individuals with meaningful access to department programs and
activities.
A. Identification of LEP Communities. Orange County shall assess the number or proportion
of LEP persons from each language group in The County to determine appropriate
language assistance services. The analysis shall include persons in Orange County with
whom your departments comes into contact while carrying out service functions. The
assessment shall include all communities who are eligible for services or are likely directly
affected by programs or activities. Departments may determine the linguistic
characteristics of an LEP population in their Orange County service area by reviewing
available data from federal, state, and local government agencies, community, and faith
based organizations. A department should also identifying and tracking the primary
language of LEP individuals that seek and receive programs and services. By regularly
collecting and updating this data, departments will be able to accurately identify and
efficiently address the changing needs of their LEP communities.
B. Quality of Language Access Services. The Department of Human Rights and Relations is
delegated with the authority to ensure that the County will take reasonable steps to
ensure that all staff or contracted personnel who serve as translators, interpreters or who
communicate “in‐language” with LEP persons are competent to do so. Considerations of
competency in light of particular tasks may include:
1. Demonstrated proficiency in and ability to communicate information accurately in
both English and the other language;
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2. Identifying and employing the appropriate mode of interpreting (e.g., consecutive,
simultaneous, or sight translation), translating, or communicating fluently in the
target language;
3. Knowledge in both languages of any specialized terms or concepts particular to the
component’s program or activity and of any particularized vocabulary used by the LEP
person;
4. Understanding and following confidentiality, impartiality, and ethical rules to the
same extent as Department staff;
5. Understanding and adhering to their role as interpreters, translators, or bi‐lingual
staff. Department liaisons shall also take reasonable steps to ensure that when
translating text, all staff or contracted personnel who serve as translators are briefed
by department staff on the context and intended audience.
6. Absent exigent circumstances, Departments shall avoid using family members
(including children), neighbors, friends, acquaintances, and bystanders to provide
language assistance services. Departments shall also avoid using individual opposing
parties, adverse witnesses, or victims to a dispute as interpreters. Using family,
friends, bystanders, or parties to a dispute to interpret could result in a breach of
confidentiality, a conflict of interest, or inadequate interpretation.
C. Types of Language Assistance Services. There are two primary types of language
assistance services: oral and written.
1. Interpretation Services. Oral language assistance service may come in the form of "in‐
language" communication (a qualified bi‐lingual staff member communicating directly
in an LEP person's language) or interpreting. An interpreter renders a message spoken
in one language into one or more other languages. Interpretation can take place in‐
person, through a telephonic interpreter, or via internet or video interpreting.
Departments shall ensure the Department of Human Rights and Relations has
designated interpreters as “qualified” prior to engaging them for services.
2. Translation of Vital Documents. Departments should proactively translate vital
written documents into the frequently encountered languages of LEP groups served
or likely to be affected by the benefit, program or service in Orange County. When
Department staff have reason to believe that an individual is LEP, the department
must respond to that LEP individual in a language he or she understands. For example,
a letter sent to a specific LEP person should be translated into the appropriate
language for that individual to ensure effective communication. Departments should
also have a language access plans in place for handling written communication with
LEP individuals in less frequently encountered languages.
a. Departments shall prioritize translation of vital documents. Classification of a
document as “vital” depends upon the importance of the program,
information, encounter, or service involved, and the consequence to the LEP
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person if the information in question is not provided accurately or in a timely
manner. The determination of what documents are considered “vital” is left
to the discretion of individual department, which are in the best position to
evaluate their circumstances and services within their language access
planning materials.
b. Types of vital documents – There are two types of Vital Documents, those
meant for the general public or a broad audience, and those that are specific
communications regarding a case or matter between an individual and the
Department. Each department should exercise its discretion in creating a
process for identifying and prioritizing vital documents or texts to translate.
Departments should ensure all translations are completed by translators who
are designated as “qualified” by the Department of Human Rights and
Relations.
c. Documents that may be considered “vital” may include, but are n ot limited to,
certain:
i. administrative complaints, release, or waiver forms;
ii. Claim or application forms;
iii. Public outreach or educational materials (including web‐based
material);
iv. Letters or notices pertaining to policies changes or updates;
v. Written notices of rights, denial, loss, or decreases in benefits or
services, or hearings;
vi. Forms or written material related to individual rights;
vii. Notices of community meetings or other community outreach;
viii. Notices regarding the availability of language assistance services
provided by the component at no cost to LEP individuals;
D. Notice of Language Assistance Services. Departments must infor m LEP individuals of their
eligibility for benefits, programs, and services in a language they understand.
Departments should assess all points of contact, telephone, in‐person, mail, and
electronic communication its staff has with the public and LEP individuals when
determining the best method of providing notice of language assistance services. A
Department should not only provide oral and written language access services, but also
must explain how LEP individuals can access available language assistance services
VI. Staff Training.
A. Language Access Training is mandatory for department directors, supervisors,
interpreters, translators, or frontline staff who encounter LEP individuals. Staff shall
receive training on identifying LEP customers and the procedures for accessing language
assistance services provided by the County. New employees will receive training at new
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employee orientation on available language access resources. Yearly training will be
available to existing staff to ensure effective implementation of the policies and
procedures.
B. Supervisors will be responsible for department level training on the department’s
language access plan. They will provide training for all staff before this new plan is
implemented. Included in the training will be a review of the Language Access Policy and
Procedures; training on utilizing translation services for written materials, and utilizing
currently used language and sign language interpreter services. Subsequent training of
new or existing staff will be the responsibility of the manager/supervisor.
C. Training for language access services will include training on LEP services, cultural
sensitivity, and customer service to help staff deliver effective and efficient language
access services to our LEP clients. The training will be delivered via a blended approach,
using a variety of tools, such as in‐person classroom style training, and on‐line webinars
designed to enhance skills, including the language skills of our employees.
VII. Bilingual Staff.
Orange County has a multi‐lingual hiring preference for positions that provide direct,
critical services to LEP clients, these position are advertised to attract bi‐lingual
candidates. Positions, the County Manager determines provide direct critical services to
the LEP community, may require that bi‐lingual persons serve in those positions. Prior to
becoming an Orange County employee, a candidate shall be tested to ensure that are
competent in each required language. Bi‐lingual employees may receive additional
remuneration.
VIII. Performance Measurement.
Orange County shall conduct an audit of language assistance services on an annual basis.
An audit consists of monitoring, evaluating and updating the Language Access Policy, plan
and procedures as needed.
IX. Language Access Plan.
The Department of Human Rights shall develop a Language Access Plan and procedures
under the direction and with the approval of the County Manager. The Language Access
Plan and any procedures shall assist County departments in defining tasks, setting
deadlines and priorities, assigning responsibility, and allocating the resources necessary
to come into or maintaining compliance with language access requirements. It will also
describes how departments will meet the service delivery standards.
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Approved December 11, 2001
Orange County Government
Limited English Proficiency (LEP) Policy
Orange County is committed to improving the accessibility of services to persons with
limited English proficiency (LEP) and to developing and implementing a system that
gives LEP persons “meaningful access” to Orange County programs and services.
Purpose
To eliminate or reduce to the maximum extent possible limited English proficiency as a barrier or
impediment to accessing core service in Orange County Government.
Background
There has been a dramatic and rapid influx of new immigrants into Orange County who have
Limited English Proficiency (LEP). For these new community members language can be a barrier
to accessing services or benefits, understanding and exercising their rights, and other information
and that may leave them vulnerable. Recognizing this, Orange County has designated eliminating
barriers and access to programs and services to the LEP community as an important goal.
Additionally, on August 16, 2000, the President signed Executive Order 13166, mandating that all
federal agencies ensure that they and their recipients of federal aid improve access to services to
the LEP population. The attached policy was drafted to support the goal and be in compliance
with the Executive Order and its policy implementation guidance. The policy as well as the
Executive Order provides no new rights or benefits but clarify existing Title VI1 responsibilities and
set forth the steps necessary to ensure “meaningful access” to services by the LEP community.
In identifying the language assistance initiatives needed that are consistent with the underlying
goal of this policy, it is reasonable to focus on those Departments within Orange County
government that have the greatest potential for interaction with the LEP population, that involve
vital exchange of information affecting provisions of service, and that grant a benefit or imposition
of a burden on the LEP population. Orange County government services can be grouped into
five categories based generally on the nature, purpose, and consequences of their interaction
with the general public and/or LEP populations.
(A) Departments whose primary mission is to serve the internal management and
administrative needs of County government. The interaction of these Departments with
the LEP population is infrequent and secondary to services that they perform.
(B) Departments whose mission is to service the policy needs of County Government. These
Departments either are not dependent on their interaction with the public or historical data
suggest that they have no significant involvement with the LEP population.
(C) Departments whose primary mission or focus is the provision of services, information, or
assistance to third parties. These Departments have the potential for serving significant
LEP populations.
1 Title VI of the Civil Rights Act of 1964 prohibits recipients of federal financial assistance from discriminating
against or otherwise excluding individuals on the basis of race, color, or national origin in any of their activities
Section 601 of Title VI, 42 U.S.C. § 2000d.
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Approved December 11, 2001
(D) Departments whose mission or focus is to serve the legal, investigative, and policy needs
of County Government in a manner that involves (and in some cases is dependent upon)
interactions with the public, including predictable and periodic interactions with identifiable
LEP.
(E) Departments whose mission or primary function is to exercise supervision and control over
special populations known to contain significant numbers of LEP individuals.
Criteria:
To determine what reasonable steps were necessary to develop a policy that provides LEP
persons with “meaningful access” to County programs and services a number of factors should
be reviewed:
(1) The number of or proportion of LEP persons in Orange County - Departments should look
at the number or proportion of LEP persons eligible to be served or encountered by the
recipient in carrying out its operation. The greater the number or proportion of LEP
persons, the more likely language services are needed;
(2) The frequency with which LEP individuals come in contact with the program – Departments
should assess, as accurately as possible, the frequency of contact with eligible LEP
persons. The more frequent the contact, the more need for the language service.
Departments should consider if with appropriate outreach to LEP persons, the frequency
of contacts will increase usage by the LEP group;
(3) The importance of the service provided by the program – Departments should consider
the importance of the activity, service, or program and whether the denial or delay of
access to service or information will have serious implication for the LEP individuals; and
(4) The resources available to the recipient – Department’s level of resources can impact the
nature of the steps it should take. Smaller departments with fewer resources are not
required to provide the same level of resources as the larger departments. Smaller
departments should combine their resources to provide meaningful access to LEP
populations.
1. Language Assistance Principle
Assisting LEP individual seeking direct County services or benefits, or where there is potential for
the direct imposition of a burden onto the individual by the County:
LEP persons should be advised that they may choose either to secure the assistance of
an interpreter of their own choosing, at their own expense, or a County interpreter
provided by the relevant Department.2 Documentation that the service was offered and
the LEP person’s election should be documented in any written record generated with
respect to the LEP person.
Departments should take reasonable steps to ensure that the interpreter services
provided are only through individuals who are competent to provide interpretive services
2 A LEP person may often look to a bilingual family member or friend or other person they are comfortable with for
language assistance, there may also be situation in which a LEP person may want to rely on County-supplied
interpretive services. (Some examples where use of an individual’s own interpreter may be justified is when an
individual has to reveal or describe information of a sensitive, confidential, or potentially embarrassing nature.
Similarly, instances where a Department’s interest may justify the use of a County-supplied interpreter is where
precise, complete or accurate translation or information is needed.)
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Approved December 11, 2001
at a level of fluency, comprehension, and confidentiality appropriate to the specific nature,
type and purpose of information at issue.
Departments should include, take into account, needed language assistance measures,
in addition to those specified in this plan, when changes occur in programs or services
where a failure to do so may result in a denial of substantially equal and meaningfully
effective services to a significant LEP population served by the County.
To the maximum extent practical, limited English proficiency shall not act as a barrier or
otherwise limit access to vital information, i.e., information publicly available in English as
to when, where, or how to access benefits or services from a Department.
2. Uniform Language Assistance Initiatives
Each Department experiencing a need for language assistance measures should take the
following action:
Oral Information. Each location accessible to the public at which vital oral
information is made available (e.g., information desks or telephone lines, certain
reception desks or areas, building entries, etc.) maintained or administered by a
Department identified as warranting language assistance measures will have in
place personnel or language assistance resources capable of providing, within one
business day, information and/or instruction in appropriate languages other than
English. Each Department should develop a plan and timetable for implementing
the following:
Have in place at points of public contact bilingual or multi-lingual staff,
appropriate translations of commonly requested information in commonly
encountered languages, or procedures for access to telephonic interpretive
services3 for use by Department personnel.
As appropriate, the written procedures for accessing telephonic language
assistance resources will be (1) inserted into every Department telephone
book (both written and electronic); (2) posted or otherwise readily available
(e.g., through the County intranet system) at every point of public contact;
and (3) distributed to every employee whose duties routinely include contact
with members of the public.
Complete and distribute to each Department, county building or, as appropriate, work
group, a listing of staff members assigned to that department, facility, or work group who
have volunteered to provide temporary language assistance services in the case of an
emergency. Name, office, physical location, business telephone number, work hours,
language, and level of fluency should identify staff members.
Written Materials. Each Department shall ensure the translation of “vital” written materials
into the language of regularly encountered LEP groups eligible to be served or to be
affected by the Department’s programs. “Vital” includes but is not limited to: written
notices of rights, denial, loss, or decreases in benefits and services; notices of disciplinary
action; consent and complaint forms; intake forms; application for participation in
3 “Telephonic interpretive services,” sometimes referred to as “language lines” involve the use of interpreters who
provide either simultaneous or consecutive translation by phone.
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Approved December 11, 2001
department’ program or activity; and notices advising LEP persons of free language
assistance.
The term “vital” depends upon the importance of the program, service, information or
encounter involved. Large documents may have both vital and non-vital information.
Written translation of only vital information is required. An appropriate “rule of thumb” in
determining vital information in a document that requires translation is:
o A Department should provide written translation of vital documents for each eligible
LEP language group that constitutes 5% or 1,000, whichever is less, of the persons
eligible to be served or likely to be affected or encountered. Translation of other
documents can be provided orally;
o If there are fewer than 50 persons in a language group that reaches the 5% trigger,
then departments do not have to translate vital materials but should provide written
notice in the primary language of the LEP language group of their right to receive
competent oral translation of the written materials, free of cost.
Please note: This applies only to the written translation of information in vital documents.
Electronic Information. Unless already in place, each Department that maintains a web
page accessible to members of the general public should include information on the
availability of language assistance through or by the Department. Where documents in
languages other than English are placed on or accessible through the web page,
information on their availability should be included in the appropriate languages on the
web home page or other initial point of access.
Signage. Where signage within a publicly accessible building maintained or
administered by a Department is provided in English, it will also be provided,
at a minimum and as soon as reasonably practical, in the two most common
non-English languages spoken in the County. In determining the two most
common non-English languages in the County, Departments should look at
available census data, and identify populations where more than 25% of the
people within a language group speak English less than well.4 Signage in fewer
languages is warranted where current demographic data establishes that the
population potentially served by the Department or facility does not include more
than one language minority group that satisfies the 25% standard. Each
Department will develop a signage implementation timetable including, where
appropriate, reasonable delays necessitated by the lack of current data on LEP
populations.
3. Department-Specific Language Assistance Initiatives. In addition to the uniform
language initiatives applicable to the department engaging in programs and activities
warranting language assistance measures, departments will implement additional
language assistance measures warranted by their particular programs, activities, and/or
target/service population and forward them to the Department of Human Rights and
Relations (HRR) to compile and forward to the County Manger.
4 “Available data” includes but is not limited to language and demographic census information pertaining to Orange
County.
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Approved December 11, 2001
4. Staff Training. All employees expected to implement the language assistance initiatives set
out in this Plan should be knowledgeable about (1) the nature and scope of language assistance
services and resources available through their department, and (2) the procedures through which
they may access those services to assist in the discharge of their respective duties. Each
department subject to this Plan will develop a plan and a timetable for the implementation of
following actions with respect to staff training:
1. Employees whose routine duties include interactions with the public will be
provided with written information on the scope and nature of available or planned
language assistance services and the specific procedures through which such
services can be accessed at the employee’s work location.
2. Each department (or, as appropriate, sub-unit) will develop and incorporate into
new employee orientation and/or training programs a module on the nature and
scope of language assistance services and the specific procedures through which
each employee can access those services.
5. Outreach. LEP individuals in need of language assistance services should have
reasonable notice of the availability of such services. Each department with significant
LEP contacts should undertake appropriate written and oral outreach efforts designed to
alert LEP communities and individuals as to the nature, scope, and availability of the
language assistance services set out in this Plan. In the area of outreach, each component
subject to this Plan will take the following actions:
Where documents are available in languages other than English, the English version will
include a notice of such availability translated into every language in which the document
is available.
Where documents are available for viewing or downloading through a component web
page in languages other than English, a tag indicating such availability in each of the
languages will be included on each web page.
To the maximum extent possible, departments will strive to inform stakeholder
organizations regarding the nature and scope of available language assistance services
through appropriate oral and written means.
6. Monitoring. Language assistance plans should be periodically reassessed to ensure that the
scope and nature of language assistance services provided under the plan reflect updated
information on relevant LEP populations, their language assistance needs, and the Departments
experience under the plan. Over the next twelve months, each Department subject to this Plan
will take the following actions to monitor the effectiveness of its language assistance initiatives
and assess the possible need for enhancements or modifications to those initiatives:
1. By the end of the third quarter of every fiscal year, each Department will advise HRR on
the approaches to be used to assess Department activities under this Plan.
2. By the end of the fiscal year, each Department will submit to HRR the results of its
assessment of its activities under this Plan, together with any proposed modifications to
this Plan. Each subsequent year, the Department will report the results of its assessment
of its activities under this Plan within the framework of such reporting mechanisms, as it
deems appropriate.
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Approved December 11, 2001
3. By the end of the first quarter of Fiscal Year 2003, after collecting Department
assessments, HRR will forward to the County Manager recommendations on proposed
modifications, if any, to this Plan for the remainder of Fiscal Year 2002 and beyond.
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Approved December 11, 2001
COUNTY DEPARTMENTS
Critical
Services
(High)
External
Services
Internal/External
Services
Informational
Internal
Services
(Low)
EMS
Health
Social
Services
Sheriff
Aging
Child Support
Cooperative
Economic
Development
Extension
Elections
Planning
Housing and
Community
Development
Human Rights
and Relations
Library
Parks and
Recreation
Register of Deeds
Revenue
Collector
Solid Waste
Transportation
BOCC Clerk
Manager
Personnel
Public Works
Purchasing &
Contracts
Environment
and Resource
Conservation
Engineer
Land Records
Natural
Resource
Conservation
Tax Assessor
Budget
Finance
IS
County
Attorney
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Approved December 11, 2001
“Tool Box” for Providing Services to
Limited English Proficiency (LEP) Clients
The components listed below are offered as suggested tools that departments may use to
accommodate the needs of non-English or limited-English speaking clients. Approaches may
vary depending upon specific departmental needs.
1) County Employees
Interpreter services may be provided through County employees as follows:
a) Employee whose primary duty is to provide interpreter services.
i) This employee may be hired by a single department or shared among departments who
need interpreter services for a major portion of the working day on a daily basis. This
type of arrangement would be recommended primarily for departments who are
categorized in the Policy as a provider of “critical services” and by the information
compiled in the departmental surveys, indicated a high need for interpreter services.
Departments seeking to add staff for this function would be subject to the new employee
approval carried out as part of the annual budget process.
b) Limited interpreter services provided by employees on a rotational basis.
i) Departments with bi-lingual employees, who have demonstrated fluency, may
participate in an interpreter pool.
ii) Employees may be scheduled during certain hours of the week to receive calls from
any County department needing interpreter assistance. This would be particularly
advantageous to departments with infrequent interpreter needs.
iii) Call lists could be available on the Intranet so a Department needing interpreter service
could easily access help while the caller was on the line.
iv) In order to experience the least amount of disruption in their regular job duties,
employees assigned to offices (as opposed to field personnel) would be most effective
in this capacity.
v) Departments may with County Manager approval offer incentives to employees
who participate in the interpreter pool when it is not a part of their primary duties.
2) Independent contractors.
a) Interpreters would be expected to execute a contract with the County prior to being used
for interpreter services.
b) Interpreters must prove competency to the County’s satisfaction prior to being included on
the list of available service providers.
c) A list of interpreters who may be willing/able to provide interpreter services is centrally
maintained.
d) Departments needing interpreter services may consult the list and schedule the interpreter
as needed.
3) Telephone Interpreter Services. (Such as the AT & T service)
a) The Department of Emergency Management has established an account for interpreter
services through AT & T and makes it available to any County department who may choose
to utilize it. Departments desiring to utilize the service should seek information in advance
from Dinah Jeffries, Emergency Management Department at 968-2050.
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Approved December 11, 2001
4) Spanish-Greeting Voice Mailbox.
a) A voice mailbox would be established exclusively for Spanish speaking only clients. The
greeting would be in Spanish and invite the caller to leave a message so someone could
call them back within a limited period of time (perhaps by the next business day).
Instructions for calling in case of emergency would be part of the voice mail message, so
response to true emergencies could be addressed immediately.
b) The messages would be picked up and the information transferred to the appropriate
service provider. This could be accomplished through current employees who may rotate
the service duty and/or an independent contractor that the County may choose to select.
c) This method of communication would be used when no other interpreter services could be
immediately accessed. It is designed as a safety net for LEP clients seeking service, but
not as first line communication.
5) Written Protocols and Training.
a) It is important that departments establish departmental protocols as it respects how
interpreter services are to be utilized pursuant to the individual departmental needs. For
example, the Health Department will assure themselves that the interpreter retained to
interpret medical information has demonstrated ability to do so accurately prior to their
being used by the Department. To avoid confusion among employees, these protocols
should be in writing and the appropriate departmental personnel trained to their use.
b) Departments seeking examples of policies and procedures for interpreter services may
wish to consider the “Orange County Health Department Policy and Procedures for
Interpreter Services”, which is available upon request to the Health Director’s office.
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