Limited English Proficiency (LEP) Plan
The purpose of this plan is to document the policies and procedures as it applies to providing meaningful access (language access) to individuals with Limited English Proficiency (LEP) while accessing services and information at Washburn Center for Children in Minneapolis, MN.
- Title VI of the Civil Rights Act of 1964, 42 U.S.C. §2000 et seq.; 45 CFR §80, Nondiscrimination Under Programs Receiving Federal Financial Assistance through the U.S. Department of Health and Human Services Effectuation of Title VI of the Civil Rights Act of 1964.
- Office for Civil Rights Policy Guidance, Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, 68FR 47311 (2003). http://www.hhs.gov/ocr/civilrights/resources/specialtopics/lep/policyguidancedocument.html
- Department of Justice regulation, 28 CFR §42.405(d)(1), Department of Justice, Coordination of Enforcement of Non-discrimination in Federally Assisted Programs, Requirements for Translation. http://www.justice.gov/crt/grants_statutes/corregt6.txt
- Communications Services, Minnesota Status § 15.441, subd (1), (2), (3), (4). https://www.revisor.leg.state.mn.us/statutes/?id=15.441&format=pdf
- Information for persons with limited English language proficiency, Minnesota Status §256.01 subd 16. https://www.revisor.mn.gov/statutes/?id=256.01
- Culturally appropriate services – Is the utilization or application of services, testing, and any other methodology that does not have the effect of subjecting individuals with LEP, and/or their families to discrimination because of their race, color, or national origin, or do not have the effect of defeating or substantially impairing accomplishment of the objectives of the program with respect to individuals of a particular race, color, or national origin.- 45 CFR 80.3(b)(2).
- Effective communication – In a healthcare delivery setting such as mental health, effective communication occurs when provider staff have taken the necessary steps to make sure that a person with Limited English Proficiency is given adequate information to understand the services and benefits available and receives the information and services for which they are eligible. Effective communication also means that a person with Limited English Proficiency (LEP) is able to communicate the relevant circumstances of their situation to the provider, and for the provider has access to the adequate information to do their job.
- I Speak Cards – “I Speak” Cards say both in English and target language “I need a (target language) interpreter.”
- Individual with Limited English Proficiency (LEP) – A person with Limited English Proficiency or “LEP” is not able to speak, read, write or understand the English language well enough to allow them to interact effectively with healthcare, social services agencies, and other providers.
- Interpreting – Interpreting means the oral, verbal or spoken transfer of a message from the source language into the target language. There are different modes of interpreting such as consecutive, simultaneous, sight-translation, and summarization.
- Language Block – Is a block of text that informs readers, in ten different languages, how they can get free help interpreting the information on a particular document or included as an insert in appropriate documents.
- LEP Implementation Team (or responsible individuals for compliance) – Individuals appointed by LEP, Director of operations to review LEP Implementation activities within Washburn Center for Children.
- Meaningful access – Meaningful access to programs, information, and services is the standard of access required of federally funded entities to comply with language access requirements of Title VI of the Civil Rights Act of 1964. To ensure meaningful access for individuals with Limited English Proficiency, service providers must make available to clients, patients and their families language assistance that is free of charge and without undue delay resulting in accurate and effective communication.
- Office for Civil Rights (OCR) – The Office for Civil Rights is the civil rights enforcement agency of the U.S. Department of Health and Human Services. OCR Region V is the regional office that enforces Title VI in Minnesota for health and human services agencies and providers.
- Primary languages – Primary languages are the languages other than English that are most commonly spoken by clientele as identified by Washburn Center for Children collection of demographic data. Currently there is 1 primary language: Spanish.
- Qualified Interpreter – A person who either has met training and competency requirements or who is a certified healthcare interpreter and in good standing before their certifying body, and adheres to the interpreter code of ethics as delineated in Section C and the National Code of Ethics and Standards of Practice for Interpreters in Health Care (National Council on Interpreting in Health Care –NCIHC).
- Sight translation – The verbal translation (transfer) of a written document from the source language into the target language.
- Translation – Translation means the written transfer of a message from the source language into the target language.
Methods of Providing Services to individuals with LEP
- Bilingual staff
- Interpreter services including in-person, by phone
- Document translation services.
Preferred Interpreter for appointments: Kim Tong Translation Service, Inc.
- Contracted Interpreters:
- Kim Tong Translation Service, Inc.
- ARCH Language Network
- ASL Interpreting Service (ASLIS)
- A-Z Friendly Languages
- Language Line (phone interpreting)
- Advanced Noticed Telephone Interpreter Services: Kim Tong, Intelligere
- Unplanned/Urgent Telephone Interpreter Services: Language Line
- Video Remote Interpreting (VRI) Services: inquire to Beth Dahline, Director of Operations.
LEP Liaison & Coordinator: Beth Dahline, Director of Operations, 612-767-4867,
Washburn Center for Children, without undue delay and at no cost to individuals with LEP and/or their families, provides meaningful access to information and service to all individuals with LEP and/or their families receiving services.
Translation of Documents
Washburn Center for Children contracts qualified translators or translating agencies to assist individuals with LEP in translating all vital documents, or documents needed to perform services.
Dissemination and Mandatory Training to Agency Staff , Volunteers, and Others
Washburn Center for Children is committed to providing LEP training to:
- All staff at new employee orientation during which staff will receive an LEP fact sheet, access to the Agency LEP plan as well as directions for accessing interpreter and translation services, AND
- At least once a year an in person training to all staff, volunteers, and contractors
Washburn Center for Children will keep record of those training sessions and individual attendance to training will be part of the Learning Management System at the Agency that has a tracking capacity. Record of this training will be kept for a minimum of five years and readily available during DHS audits, investigations, or any proceeding and as required by the law.
This training is to include at least the following:
- Title VI of the Civil Rights Act of 1964
- How to work effectively with interpreters, and
- Any other cultural issues related to delivery of information and services to individuals with LEP served by Washburn Center for Children.
This policy is added to the Manual of Policies and Procedures of Washburn Center for Children.
Dissemination of Language Access Information in Public Areas
Washburn Center for Children makes available to individuals with LEP:
- Notice of language access services by posting in public areas the “Language Poster”, available through DHS public Web site (https://edocs.dhs.state.mn.us/lfserver/Legacy/DHS-4739-ENG )
- “I need an interpreter” card available in ten languages and from DHS public Web site (https://edocs.dhs.state.mn.us/lfserver/Public/DHS-4374-ENG)
Annual Review of LEP Plan
Washburn Center for Children reviews annually its LEP plan to adjust or modify its contingencies based on demographic data collected by Washburn Center for Children during its delivery of information and services to individuals with LEP throughout the year.
Washburn Center for Children upon DHS request will complete and submit DHS LEP Plan review on an annual basis or as often as requested by DHS.
Collection of Data & Its Analysis
Washburn Center for Children is committed to monitor and make reasonable adjustments to comply with Title VI requirements. Washburn Center for Children will collect:
- DOB, gender, preferred spoken language, preferred written language, needs interpreter (Yes, No), cultural background, ethnicity, socio-economic status.
The purpose of collecting these data is to provide competent clinical services as well as for reporting purposes.
When outcomes are evaluated our data enables Washburn Center for Children to identify how any of the above factors may impact client outcomes. It also enables the Agency to identify demographic trends and changes over time.
Individuals with LEP have the right to file a formal complaint with:
- Washburn Center for Children, Grievance Coordinator:
Jennifer Gozy, PsyD, LP
Washburn Center for Children
1100 Glenwood Avenue, Minneapolis, MN 55405
- Minnesota Department of Human Services (DHS), Limited English Proficiency (LEP) Coordinator:
O. Box 64997
Saint Paul, MN
MN Relay 711 or 1-800-627-3529
- Office for Civil Rights (OCR), Region V – Chicago, IL
Celeste Davis, Regional Manager
Office for Civil Rights
S. Department of Health and Human Services
233 N. Michigan Ave., Suite 240
Chicago, IL 60601
Voice Phone (800) 368-1019
TDD 800- 537-7697