Guide to Developing a Language Access Plan

The first step in developing a language access plan is to gather information about the needs of current and prospective patients, consumers, or clients. For populations whose preferred spoken and written language is other than English, including those with limited English proficiency (LEP), identify which languages they prefer. Identify other groups with communication issues, such as those who are hard of hearing and those who are visually impaired. Examine the ways in which individuals with these communication issues interact with your organization and the challenges they face.

Once you have done so, identify ways to resolve those difficulties. These can include adding additional internal resources, contracting with outside professional language service providers, or a combination of the two. It may benefit a larger business or government agency, for example, to have an on-site interpreter available during regular business hours if it has a large LEP clientele that speak one or several common languages. In addition, the business or agency could contract with outside professional interpreters to provide interpretation and translation services for LEP speakers of other languages on specific days or on an as-need basis.

Your needs may change over time as your organization or the population it serves changes. Your language access plan should include ways to reassess your organization’s needs and determine whether your current resources are sufficient and appropriate.

Once it has identified your communication challenges, your plan should enumerate the services that you offer to resolve the issues. It should include the interpreting and communication enhancement services your organization currently offers, when they are used or accessed, and the mechanisms in place for providing them. This includes your solutions for on-site interpreting, video remote interpreting, and phone interpreting as well as off-site professional providers. It should specify:

• Your language services provider for each service offered
• How services are available (e.g., on demand, by request, or on certain days/times)
• Which languages are available
• How interpreters are selected, trained, and certified if appropriate
• How your organization ensures interpretation accuracy
• How often these processes will be reviewed

 For individuals with LEP, provide a description of the types of services, such as in-person interpretation, video remote interpretation, and translation of documents and a list of available languages for each service. For individuals who are hard of hearing, provide information about hearing-assistive technology like assistive listening devices, hearing loops, or alertive devices that may be helpful as well as services like captioning, text transcription, and voice-to-text. Ever-evolving digital technology like mobile apps and tablets can help students, patients, and other individuals communicate immediately and efficiently in situations where time is of the essence. If your organization offers any additional technological resources or contracts with professional communications providers, identify them in this section of your plan.

A written language access plan helps both your employees and the intended beneficiaries understand what communication resources are available and how to access them. It should also identify the individuals in your organization whose responsibility it is to help make those connections.

Having a wide variety of resources available is only beneficial if users know about them and how to access them. Your language access plan should identify how you will let your patients, clients, customers, and other individuals who may wish to utilize these communication resources know about their availability. You may wish to post multilingual notices or play audible announcements in your workplace, especially in highly trafficked areas like entrances, break rooms, lobbies, waiting rooms, bathrooms, and hallways. Employees who interact with the public might add the languages they speak to their identification badge or their nametag.

Also, consider whether to add information about the communication assistance services that you have available to your website, marketing materials, print advertisements, mail and email campaigns, and other public-facing content. Having multi-lingual website options, videos, downloadable content, educational materials, and other self-serve digital options can be cost-effective ways to help you connect with a wider demographic of potential clients, customers, patients, or associates.

In its own language access plan, the U.S. Department of Health and Human Services (HHS) outlines several steps that the agency implements to notify those who need language services of its available interpretation resources and commitment to serving LEP populations. These steps include

• Designating an office or individual responsible for notifying individuals with limited English proficiency who contact the agency of the available interpretation resources
• Distributing federal resources prohibiting discrimination against LEP individuals to its grantees, providers, contractors, and vendors
• Using public service announcements, non-English media, and community and faith-based resources to reach target audiences and notify them of communication services
• Prominently displaying appropriate language taglines on vital documents, web pages currently available in English only, technical assistance bulletins, and other outreach material
• Highlighting the availability of consumer-oriented materials in other languages on the department’s website.

Your language access plan should provide a description of how your organization will train its staff on its internal policies and procedures for providing language assistance services. Your organization should ensure that all employees understand the importance of providing language assistance and are able to connect individuals with the resources available. All employees should be aware of your language access policies and procedures and how to access interpretation or translation services when needed. Those who interact directly with customers, patients, or clients should be trained to work with interpreters as well as how to communicate effectively and respectfully with LEP individuals. Designate an office or a person to be responsible for this training.

You may choose to conduct internal training, contract with a professional language services provider, or a combination of both. Ongoing training should occur regularly enough to ensure that all employees understand whom to contact to access language and communication assistance services and what services are available. Continuing education can also help employees learn about new assistive technology and updates to best practices as community preferences and standards evolve.

Finally, your language access plan should set out a framework for how your organization will monitor the efficacy of its efforts. Based on these evaluations, you should be able to update your plan, policies, and procedures as needed to ensure that your goals are being met. Determine metrics for success based on your industry, company, and community.

Some industries, like health care, can utilize outside reviews like the yearly “Secret Shopper” program conducted by the Center of Medicare & Medicaid Services (CMS) as part of their evaluation metrics. This program measures health care providers’ quality of service and compliance with Medicare regulations by enlisting “secret shoppers” to conduct telephonic, virtual, and in-person healthcare interactions. Providing fast, efficient, accurate, and easy-to-access language services for shoppers who wish to interact in a language other than English or who have other communication issues can have a powerfully positive result on a healthcare organization’s CMS score. Conversely, failing to provide appropriate communications resources for patients can result in low scores and additional penalties from CMS.

Setting clear evaluation metrics will allow you to see how well you are doing and adjust as necessary. In conjunction with a regular re-assessment of your needs, you can add, subtract, or change services to respond as your organization and community’s needs evolve.

Further, regular evaluation can help you identify ancillary benefits of providing improved communication services. In an educational setting, offering a multilingual educational program not only improves the performance of LEP/ELL students but also can provide significant benefits to the community at large. These benefits include helping English-proficient students learn additional language skills, preserving culture, fostering respect for cultural diversity, and broader community involvement in the schools.