Issuance No: A28
Issuance Date: December 3, 2019
Subject: Accessibility Policy – Persons with Limited English
In accordance with OWD Issuance 06-2014
This policy (and the corresponding Office of Workforce Development [OWD] Issuance) is in place to ensure LEP individuals have meaningful access to all programs and services; and are able to participate effectively regardless of their ability to speak, read, write, or understand English.
Identifying language barriers and developing strategies to overcome those barriers are essential for agencies to comply with federal requirements. These requirements are within several guidance documents, including the following:
Title VI of the Civil Rights Act of 1964 prohibits recipients of federal financial assistance from discriminating based on national origin by, for example, failing to provide meaningful access to individuals who are LEP;
Executive Order 13166 signed by the President in August 2000 and titled “Improving Access to Services for Persons with Limited English Proficiency” contains two major initiatives. The first initiative aims to better enforce and implement Title VI of the Civil Rights Act of 1964 by requiring federal agencies that provide federal financial assistance to develop guidance to clarify obligations for recipients of such assistance. The second initiative requires all federal agencies to meet the same standards as federal financial assistance recipients in providing meaningful access for LEP individuals to federally conducted programs.
Section 188 of the Workforce Innovation and Opportunity Act (WIOA) and its implementing regulations provides that no person shall be subjected to discrimination based on national origin under any program or activity that receives federal financial assistance.
Job Center staff must use “I Speak” cards to allow the customer to point to the language they are familiar with to ensure we are connecting them to the appropriate resource for interpretation. The Job Center also has access to a real time over-the-phone interpretation service through the Language Link Language Line.
Job Center staff will partner with the local Adult Education Literacy (AEL) office for referrals and outreach. AEL providers serve English language learners; Job Center staff are encouraged to make referrals to AEL for customers wishing to advance their English proficiency.
The local Equal Opportunity Officer will conduct an on-site monitor of each service provider. During this monitoring, practices that concern serving customers with limited English proficiencies will be reviewed. On an annual basis, a data analysis of all programs in the region will review performance of individuals who are limited English proficient.
The local Equal Opportunity Officer, in partnership with the WIOA Title I service providers, will develop outreach plans based on multiple resources including, but not limited to, feedback from Job Center Staff, comments and concerns from customers/participants, and results of the Equal Opportunity Officer’s data analysis. The purpose of the outreach plans will be to enhance services to limited English proficient individuals. The individual service provider is responsible for implementing the outreach plan within their programs. The local Equal Opportunity Officer will follow up with each service provider to ensure the outreach plan is being followed.