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Language Access Plan for Persons with Limited English Proficiency

Purpose

The purpose of this Language Access Plan (LAP) is to establish policy and provide guidance in developing and implementing reasonable efforts to eliminate or reduce “Limited English Proficiency” (LEP) as a barrier to accessing University of Oregon (UO) programs, activities, or events as required by Executive Order (EO) 13166, “Improving Access to Services for Persons with Limited English Proficiency” (August 11, 2000), which prohibits discrimination and requires that each federal department and agency examine the services they provide to the public and, accordingly, develop and implement a system by which LEP persons can have meaningful access to those services without unduly burdening the fundamental mission of the agency.

Scope

This plan covers UO interactions with LEP individuals that occur in the State of Oregon.

Key Terms

The following are terms associated with the goals of the UO Language Access Plan and its implementation:

Interpretation and Translation: Interpretation involves oral communication and the immediate communication of meaning from one language into another. An interpreter conveys meaning orally. From the standpoint of the user, a successful interpretation is one that faithfully and accurately conveys the meaning of the source language orally, reflecting the style and cultural context of the source message, without omissions, additions, or embellishments on the part of the interpreter. Professional interpreters are subject to specific codes of conduct and should be trained in interpretive skills, ethics, and subject-matter language. Translation involves written communication from one language to another. Translation services do not occur in real-time. UO employees utilizing interpreters and translation services should request information about certification, qualifications, experience, and training.

The UO utilizes Language Line, https://www.languageline.com/ when providing interpretation and translation services to LEP individuals, including for videoconferencing or telephonic interpretation. Language Line provides telephonic interpretation services and has in place quality control and privacy safeguards.

Limited English Proficient Persons: Persons whose primary language is not English and who have a limited ability to read, speak, write, and/or understand English.

Policy

The UO follows the policy in the DHS Language Access Plan (LAP) and, therefore, adopts the following specific policy. Its intent is to provide meaningful access for LEP individuals to its programs and activities within the state of Oregon by providing quality language assistance services in a timely manner. In this regard, the primary goal of this policy is to provide meaningful access to UO programs, benefits, and services, and maintain compliance with civil rights laws by communicating effectively with LEP individuals in languages other than English.

This policy and plan will be accessible and available at: https://investigations.uoregon.edu/language-access-plan-persons-limited…

LEP Communities Served or Encountered

Oregon is home to millions of individuals from different cultures and backgrounds. A significant number of whom have limited English proficiency. The 2017 ACS data shows that among those 5 years and older in Oregon, 5.5%, or 215,262 individuals, reported that they spoke English less than “very well.” According to the 2021 ACS data, 15.3% of Oregon’s population speaks a language other than English at home. The most commonly spoken languages other than English are Spanish (8/9%), Chinese languages, and Vietnamese, with 5.5% of the Oregon population reporting speaking English less than very well.

Tracking and Monitoring Procedures

With regard to the UO/DHS grants, Sponsored Projects at the University of Oregon and OICRC will work in a collaborative manner to ensure compliance using the Civil Rights Evaluation Tool. Sponsored Projects and OICRC can work together in conducting compliance reviews, identifying gaps in providing services to LEP persons, and providing technical assistance to achieve compliance. The University of Oregon will conduct a review on a biennial basis and update this plan as necessary or as required by the Department of Homeland Security (DHS).

The primary goal of UO’s LAP is to eliminate or mitigate LEP as a barrier to accessing UO’s programs, activities, or events. In this regard, the UO’s priorities will focus on identifying the most common and the most critical language access needs. Another goal is to ensure the LAP Working Group is properly trained on pertinent areas of Title VI.

Below are current objectives with the target dates for implementation:

  • January 31, 2023: Identify protocols in place for UO personnel/units/operational components to identify language access services provided to LEP persons.
  • February 28, 2023: Determine proper audience and level of LAP training required.
  • March 31, 2023: Conduct evaluation of UO recipient organizations, at least two recipients per year.

Language Assistance Resources and Measures

Regardless of the type of language services provided, quality and accuracy of those services is critical to avoid potential consequences to both LEP individuals and the University of Oregon. The correct mix of interpretation and translation services should be based on what is both necessary and to provide meaningful access to LEP individuals.

  • Real-time telephonic interpretation services are available to program participants via Language Line. Program, https://www.languageline.com/. Program staff may access The following language access resources are available to program participants:
  • The University will translate key documents in Spanish and Mandarin Chinese. We should consider translating the reporting policy in Spanish and Mandarin Chinese. We could create an abbreviated reporting form in Spanish and Mandarin Chinese.
  • Information about language translation services being available at no charge is available on the UO website. Front-line staff will be instructed on how to assist customers with language access services.
  • Front-line staff will be provided with resources and instructions on how to respond to LEP individuals, such as the following:
    • UO LEP Policy Statement
    • “I-Speak” language list to enable the LEP individual to self-identify their language needs. While bilingual staff would only be used to interpret if they are qualified to do so, soliciting the assistance of bilingual staff would be a helpful interim measure while certified translation/interpretation services are being secured.
    • List of bilingual staff to solicit assistance.
    • The name of the approved vendor to secure translation services.

Notice to LEP Persons

The UO will make reasonable efforts to ensure the public is aware of its LEP policy and existing options to access language assistance services. This information will be provided in English and translated into most frequently used language(s), other than English, based on the population needs. The UO will provide notice as follows:

  • Using a telephone voicemail menu. The menu could be in the most common languages encountered. It should provide information about available language assistance services and how to receive them.
  • Presentations and/or notices at schools, religious organizations, or other community-based organizations.

Staff Training

Staff training is an important step to provide meaningful access to LEP individuals. Training will be mandatory for staff with the potential to interact or communicate with LEP individuals, staff whose job it is to arrange for language assistance services, and managers. Even if management staff may not interact regularly with LEP persons, they should be fully aware of, and understand the plan so they can reinforce its importance and ensure its implementation by staff. All staff will periodically receive refresher courses on policies, processes, and resources – particularly as language access methods evolve. The University of Oregon policy and the availability of translation and interpretation services at no cost to the customer will be promoted to staff.

Trainings will focus on the importance of providing language assistance services and include procedures to help staff identify the language needs of an LEP individual and access, as well as provide the necessary language assistance services, work with interpreters, request document translations, and track the use of language assistance services. Training will occur annually.

Contact Information and Assistance

For more information about UO’s Language Access Plan, the public may contact the Chief Civil Rights Officer at (541) 346-3123 or oicrc@uoregon.edu.

Complaints about language access in UO programs and activities may be filed with the DHS Office for Civil Rights and Civil Liberties (CRCL). For more information about filing
complaints with CRCL, see https://www.dhs.gov/crcl, or call CRCL at (202) 401-1474 or 1 (866) 644-8360. Complaints may be filed in any language.

Conclusion

The UO policy is intended to provide meaningful language access to individuals with Limited English Proficiency needs. Accordingly, UO will continue to work to ensure compliance with the goals of nondiscrimination as required by Executive Order (EO) 13166 and Title VI of the Civil Rights Act of 1964.