Position Paper
VLSSE
Provision of Services to the Limited English Proficiency (LEP)
Population
July 2007
Overall Guiding Principle:
To ensure that every individual seeking help from local agencies is provided access to
and understands the information provided to them regarding benefits, programs,
information and services regardless of their ability to speak English.
Background:
Title VI of the 1964 Civil Rights Act states that “No person in the United States shall, on
the ground of race, color or national origin, be excluded from participation in, be denied
the benefits of, or be subjected to discrimination under any program or activity receiving
federal financial assistance.” Different treatment based on a person’s inability to speak,
read, write, or understand English may be a type of national origin discrimination. In
addition, Executive Order 13166 further defines the enforcement of Title VI through
improving access to services for person with limited English proficiency.
Proposal 1:
The Virginia Department of Social Services (VDSS) should support local agencies in the
provision of high quality services to limited English proficiency (LEP) residents of the
Commonwealth. The Virginia Department of Social Services should:
 Conduct regular reviews of the primary languages used by residents. This would
identify the specific language needs for the provision of interpretation and/or
translation services, as well as other services that may be needed for the LEP
population across the Commonwealth,
 Develop forms, brochures, documents and automation tools necessary to serve
the LEP population and update them, as needed,
 Negotiate and directly fund a statewide contract for interpreter and translation
services for use by local agency staff,
 Modify current information technology (IT) systems to enable local agencies to
identify the language needs of the population they serve and,
 Provide services and support to local agencies to ensure services are delivered by
local agency staff at the same level as provided to native English speakers
Rationale:
 Ensures services at the local level are uniformly and consistently provided
throughout the Commonwealth to comply with federal regulations and provides
excellent customer service.
 The LEP population continues to increase in all localities. Interpretation and
translation services must be used to ensure timely and accurate determination for
public assistance.
 Local agencies need to have the ability to address the needs of the LEP population
they serve. Presently, local agencies can not get the data regarding language
usage for our clients from the IT systems.
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Proposal 2:
To the extent that services and support are not directly provided to local agencies, VDSS
should provide funding reimbursement over and above current administrative allocations
for local agencies to:
 Contract for the purchase of vendor services for interpretation and translation
services, if they are not provided through a state contract.
 Purchase or separately reimburse local agencies for needed supplies and
equipment, such as speaker phones, phones and phone service capable of
conference calls, brochures and other aids.
 Establish a certification program that tests bilingual staff on their foreign
language proficiency.
 Provide additional compensation to bilingual employees that have been certified
as proficient in a foreign language that is needed to serve the LEP clients and
comply with Title VI.
Rationale:
 The LEP population served by local agencies continues to increase. Local
agencies continue to adjust the manner in which they provide services to
accommodate the needs of this population. Local agencies frequently purchase
interpretation and translation services from outside vendors to serve LEP clients.
The expenses that are incurred by local agencies can be significant.
 Using vendors to provide interpretation and translation service is a practical way
in which to address the multitude of languages used by our client population.
 In order to provide interpretation services telephonically, special equipment such
a three-way speaker phones, must be purchased and available to local agency
staff.
 It’s essential to have bilingual employees. In order to compensate them for their
foreign language skills and the additional services they provide, some local
agencies currently provide a stipend. The provision of a stipend is useful to
attract and retain much needed bilingual staff.
 For local agencies to comply with Title VI, state funding must be available for
serving the LEP population. The fiscal capacity of individual localities should not
affect the quality of services to the LEP population.
Benefit:
Improved access to and utilization of services provided by local agencies for the LEP
population and compliance with federal mandates. Improved efficiency and quality of
services, both customer service and accuracy of information exchanged between
customer and agency, thus reducing the possibility of case errors.
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Proposal 3:
The Virginia Department of Social Services (VDSS) should provide appropriate staffing
levels for local agencies by:
 Ensuring that the Hornby-Zeller (HZ) workload study, currently being conducted,
considers the additional time that it takes to serve the LEP population.
 Funding additional staff required, identified by HZ, for local agencies to serve the
LEP population.
Rationale:
 Serving the LEP population takes a great deal of additional staff time. When
interpreters are used to conduct interviews, it can take twice as long to conduct an
interview. Caseworkers first need to explain everything to the interpreter who
then relays the information to the LEP individual, and then back to the
caseworker.
 A bilingual caseworker’s interview may also take longer to complete because of
the need to explain the meaning of technical terms and concepts that can be
complex and totally foreign to the customer, and difficult to translate.
 Cultural differences must also be taken into account during an interview with
those who are new to this country as well as LEP clients. This also takes
additional time during the interview process.
 The LEP population is often more disenfranchised and frequently will use their
caseworker as a point of contact for any type of information/questions that they
may have, not just social services related information. Typically, a bilingual
caseworker becomes the customer’s lifeline to their new world.
 LEP clients usually require additional verifications, especially with respect to
alien status issues.
Benefit:
In addition to improved access to and utilization of services provided by local agencies
for the LEP population, quality and timeliness of services provided would be increased
thus reducing the demands for interventions by other agency service providers.
Proposal 4:
The Virginia Department of Social Services (VDSS) should provide mandatory training
to staff in the requirements of the provision of services to the LEP population.
Rationale:
 Consistency between local agencies in the provision of services to the LEP
population.
 Appropriate usage of interpreter services such as when it is required and who is
qualified to act as an interpreter
Benefit:
Compliance with Title VI by all local agencies as well as high quality service delivery.
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