Language Access Plan

Access Plan Contents:

Related Documents:


Questions and Answers About Cleveland's Language Access Plan

Why does Cleveland need to implement a Language Access Plan?

The City of Cleveland is committed to providing inclusive and welcoming service to all residents. As part of that commitment to inclusion, the city will ensure meaningful access to resources, services, and engagement regardless of language. 

In addition to the City of Cleveland’s commitment, all federally funded agencies are required to provide limited English proficient individuals with meaningful access to programs and activities under various statutory and regulatory requirements including but not limited to:

What are the city's primary language groups?

The city's top-spoken foreign languages are:

  1. Spanish (7.4%)
  2. Arabic (0.9%)
  3. Chinese [Mandarin, Cantonese] (0.7%)
  4. Russian [including Slavic and Serbo-Croatian rooted languages] (0.7%)
  5. Indic [Hindi, Urdu, Indo-European] (0.6%)
  6. French [combined with variety of African dialogues] (0.4%)
  7. Nepalese [newly arrived] (0.1%)

Source: U.S Census Bureau, 2010-2014 American Community Survey 5-Year Estimates

The following table shows the estimates for limited English speaking households in the ClevelandElyria Metro Area:

Source: U.S. Census Bureau, 20112015 American Community Survey 5-Year Estimates

What does this plan cover?

This plan includes a Language Access Plan Implementation section, a Language Access Policy Directives section, and a Language Access Procedures section.

The Language Access Plan Implementation section helps management and staff understand their roles and responsibilities with respect to overcoming language barriers for limited English proficient individuals. The Implementation Plan includes five phases:

  • Phase 1: City-wide assessment of Language Access needs
  • Phase 2: Implementation of phone interpretation services
  • Phase 3: Implementation of written translation services
  • Phase 4: Employee Training and Ongoing Monitoring
  • Phase 5: Community Outreach

The Language Access Policy Directives section sets forth standards, operating principles, and guidelines that govern the delivery of language access services.

Finally, the Language Access Procedures section provides the “how to” for staff. It specifies for staff the steps to follow to provide and deliver language services to limited English proficient individuals.

This plan also includes exhibits of instructional and informational materials that are essential to implementation.


Responsible for Ensuring Implementation and Ongoing Monitoring

A Language Access Working Group was formed with members from Cleveland City Council, the Office of the Mayor, and the Office of Information Technology and Services. The Group works collaboratively with all City departments to ensure implementation and ongoing monitoring. .

Points of Contact:

The Language Access Working Group is comprised of staff from the following offices:

  • Alexander Lackey, Government, Legislative, and International Affairs Coordinator, Office of the Mayor Email  
  • Olivia Ortega, Policy Research Fellow, Cleveland City Council Email
  • Rick Roscoe, 311 Call Center Manager, Division of Information Technology & Services Email
  • Chia-Min Chen, Asian Liaison, Community Relations Board Email

Acknowledgements:

The City of Minneapolis’ guide “Minneapolis in Any Language” and the City of Chicago’s “Bridge the Language Gap,” among other resources such as www.lep.gov were taken into consideration for the development of the following procedures and policies. Additionally, Legal Aid Society of Cleveland reviewed and offered suggestions to improve this Plan in collaboration with the Language Access Working Group.


Definitions

  • 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 meaning.
    1. In-person Interpretation: Where a qualified interpreter, who is present, listens to communication in one language and orally converts it into another language (either consecutively or simultaneously) while retaining the meaning.
    2. Telephonic Interpretation: Where a qualified interpreter, who is on the phone, listens to communication in one language and orally converts it into another language (either consecutively or simultaneously) while retaining the meaning.
  • 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 communications (e.g., speaking or understanding), but still LEP for other purposes (e.g., reading or writing).
  • Meaningful access: Language assistance that results in accurate, timely, and effective communication with the LEP individuals. For LEP individuals, meaningful access denotes access that is not significantly restricted, delayed, or inferior as compared to programs or activities provided to English proficient individuals.
  • Qualified Interpreter for an individual with limited English proficiency means an interpreter who via a remote interpreting service or an onsite appearance:
    1. Adheres to generally accepted interpreter ethics principles, including client confidentiality;
    2. has demonstrated proficiency in speaking and understand both spoken English and at least one other spoken language; and
    3. is able to interpret effectively, accurately, and impartially, both receptively and expressly, to and from such language(s) and English, using any necessary specialized vocabulary, terminology, and phraseology.
  • Qualified Translator means a translator who:
    1. Adheres to generally accepted translator ethics principles, including client confidentially;
    2. have demonstrated proficiency in writing and understanding both written English and at least one other written non-English language; and
    3. is able to translate effectively, accurately, and impartially to and from such language(s) and English, using any necessary specialized vocabulary, terminology, and phraseology.
  • Translation: The replacement of written text from the source language into an equivalent written text in the target language.
  • Vital Documents: A document will be considered vital if it contains information that is critical for obtaining services and/or benefits, or is required by law. Vital documents include, for example: applications; consent and complaint forms; notices of rights; notices of disciplinary action; notices of advising LEP persons of the availability of free language assistance; rulebooks; request forms; grievance forms; health request forms; written tests that do not assess English language competency, but rather competency for a particular license, job, or skill for which English competency is not required; and letters or notices that require a response from the beneficiary or client. Non-vital information includes documents that are not critical to access such benefits and services.

Full list of definitions can be found in the Foreign Languages Services Ordering Guide , which was prepared by a Federal interagency working group called the Language Services Procurement Committee.


City of Cleveland Language Access Plan Phases 1-5

Phase 1: City-wide Assessment of Language Access Needs; Date of Assessment Spring 2016

  • Implementation of Assessment:
    • Survey sent to each director/commissioner to obtain information on each department’s language access needs.
    • Language Access Working Group contacted each department as necessary to obtain additional information on needs.
    • Survey/meeting results compiled and analyzed to determine list of vital documents that needed translation and to determine need for interpretation services.
  • Assessment results:
    • 74 vital City documents were compiled for translation to Spanish.
    • Analysis determined need for phone interpretation services available to alldepartments, particularly public-facing departments whose employees regularly interact with City residents.

Phase 2: Implementation of Phone Interpretation Services; Date of implementation July 2016

  • Implementation:
    • Purchase order was initiated with vendor in July 2016 for phone interpretation services for every department.
    • The service has been live in the IT Call Center since July 2016.
    • The service will effectively go live for all departments when Phase 4 employee training is completed in 2017

Phase 3: Implementation of Written Translation Services; Date of Implementation September-November 2016

  • Implementation:
    • Purchase order was initiated with vendor in September 2016.
    • 74 vital City documents were received from the vendor as translated Spanish copies in November 2016.
    • Documents will be distributed to appropriate departments in 2017 during Phase 4 employee training.
    • Working Group will assess the need for additional document translation on a departmental basis.
    • Working Group will establish the use of “Babel” notices, notices placed at the bottom of vital documents to assist residents who need translated versions.

Phase 4: Employee Training and Ongoing Monitoring; Date of Implementation: January 2017-Present

  • Implementation:
    • In collaboration with TV20, a brief training video will be sent out to all employees. The video instructs employees on how to effectively use the phone interpretation service.
    • Language Access Working Group will work with all departments on assessing and meeting all training needs and gaps.
    • Working Group will work collaboratively with the Department of Human Resources to roll out effective training initiatives for new and current employees to use phone interpretation services.
    • Language Access Working Group will meet with department representatives on a quarterly basis to review phone interpretation usage and support any additional language access needs.
    • Language Access Working Group will have ongoing discussions around creating a complaint process for residents who have concerns about the provision of language access services.

Phase 5: Community Outreach; Date of Implementation April 2017

  • In collaboration with TV20, Working Group will roll out series of commercials advertising new services in various languages.
  • Working Group with work with Community Relations Department on outreach visits and informational materials to community groups that work with LEP residents.
  • Working Group will work with area organizations like Global Cleveland to conduct outreach to LEP residents.

Implementation Timeline

Task Completion Dates

  • Phase 1 Spring 2016
  • Phase 2 July 2016
  • Phase 3 November 2016
  • Phase 4 January 2017
  • Phase 5 May 2017

 Language Access Policy Directives

The following policy directives are based on the recommended policy directives put forth in the Language Access Assessment and Planning Tool for Federally Conducted and Federally Assisted Programs, a document prepared by the U.S. Department of Justice Civil Rights Division.

Notice of Availability of Services

Signage materials indicating the availability of interpretation services include Language ID Laminated Guides, Language ID Posters, and Language ID Desktop Displays for departmental reception areas. Materials will be distributed to departments as needed and will indicate to LEP residents the availability of interpretation services in their native language.

In addition, City of Cleveland will implement the use of “Babel” notices, or notices that indicate the availability of language assistance services on vital documents in at least the top three spoken foreign languages. It is City policy to include babel notices on public meeting announcements and invitations to inform LEP individuals that interpreting services are available upon request.

Below are sample babel notices informing individuals with limited English proficiency of language assistance services:

Sample notices in additional langauges can be found here.

Written Translation Policy

City of Cleveland will provide professional translation of vital documents free of charge and in a timely manner to people who speak little or no English if requested or if necessary to ensure effective accessibility to City resources, services, and engagement. To ensure this delivery of service, City of Cleveland has a contract with LanguageLine Solutions® to provide translationservices by qualified translators.

Vital Documents Policy

A document will be considered vital if it contains information that is critical for obtaining services and/or benefits, or is required by law. Vital Documents include, for example: applications; consent and complaint forms; notices of rights; notices of disciplinary action; notices of advising LEP persons of the availability of free language assistance; rulebooks; request forms; grievance forms; health request forms; written tests that do not assess English language competency, but rather competency for a particular license, job, or skill for which English competency is not required; and letters or notices that require a response from the beneficiary or client. Non-vital information includes documents that are not critical to access such benefits and service such as:

  • handbooks;
  • third party documents, pamphlets or forms;
  • general information that can be found on the website (which is translatable)

NOTE: While many vital documents will be immediately available in other languages on the City's website, not all vital documents will be translated. Upon request, any vital document must be translated in a timely manner in the requested language.

Policies for Interpreting

City of Cleveland will provide professional in-person and telephonic interpretation free of charge and in a timely manner to LEP persons if requested or if necessary to ensure effective access to City resources, services, and engagement. To ensure this delivery of service, City of Cleveland has a contract with LanguageLine Solutions® to provide telephonic interpretation services by qualified interpreters. To ensure the delivery of inperson interpretation services, the Language Access Working Group has established relationships with various Ohio Supreme Court certified and provisional interpreters.

Below are the policies for City of Cleveland employees when providing interpretation service:

  1. Interpreters must be offered at no cost, to individuals who speak little or no English if such individual requests interpretation services or if the city staff member determines communication is not possible without interpretation services. Interpretation services must be provided in a timely manner.
  2. Interpretation can be provided for public meetings and events if requested with at least a five-business day notice. Public meeting notices shall include a line advising LEP residents that interpreters will be provided upon request if there is at least 5 business days notice.
  • Sample babel notices can be found under Notice of Availablity of Services above
  • All interpreters must:
  • a. be linguistically competent (have the ability to demonstrate fluency);
    b. have prior professional experience;
    c. practice with cultural humility regarding the English language learners situation and culture; and
    d. abide by the City of Cleveland’s code of ethics and professional standards

        4. Volunteers, family members or friends should not be allowed to interpret unless they are competent (demonstrate fluency)

         5. Children MAY NOT interpret

    It is the responsibility of the Language Access Team to ensure that all inperson interpreters and the City employees that interact with services uphold these policies. For questions, comments, and concerns, please contact a member of the Working Group (contact information can be found under Points of Contact).


    Information and Technology Services Policy

    The City of Cleveland’s Office of Information and Technology Services will add a translation widget powered by Google Translate to all websites maintained by the City. This will allow online users to access information remotely in any language.

    Any translated content that a department has available for public download should also be submitted to the IT department for upload to the site. If an application is available for download from a City website, the respective translated application should be available for download as well.


    Language Access Procedures

    Procedure to get additional documents translated

    The City of Cleveland has a contract with a professional translating company, LanguageLine Solutions® , and documents should only be translated through their services or by a professional translator. Employees should not use free online translation services without a professional translator reviewing the content. Residents can request document translation services from employees or employees can utilize translation services when appropriate to allow for effective access to services. Submission process instructions will be provided to departments with instructional packets.


    Procedure to Provide an In-person Interpreter for City Business or Events

    The City of Cleveland maintains relationships with Ohio Supreme Court certified and provisional interpreters on a Memorandum of understanding basis. Residents can request inperson interpretation services from employees or employees can utilize inperson interpretation services when necessary to provide effective access to City services or events. A pointofcontact from the Language Access Working Group will be assigned to each department for inperson interpreter requests.

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