1. Know whether Title VI’s limited English proficiency (LEP) requirements apply to your business or agency.
    1. Title VI requires that persons with limited English proficiency must be able to effectively participate in or benefit from federally assisted programs and activities.
    2. All recipients of federal financial assistance from HUD must comply with Title VI LEP requirements.
      1. Financial assistance includes grants, training, equipment, and other assistance.
      2. Examples of who must provide LEP access:  state and local governments, public housing agencies, assisted housing providers, Community Development Block Grant and HOME Investment Partnership Program recipients.
  2. Have a plan for identifying LEP persons.
    1. LEP persons are defined as:  Persons who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English.
    2. One good option for identifying LEP persons is through using “I Speak” cards, which allow a person to point to the language they speak.
      1. These cards are available through the Department of Justice at www.justice.gov/crt/about/cor/Pubs/ISpeakCards.pdf
  3. Perform a Four Factor Analysis:
    1. The number or proportion of LEP persons eligible for your services.
    2. Frequency with which LEP persons come in contact with your program/office.
    3. Nature and importance of the program, activity, or service you provide.
      1. Services such as housing, food, education, health care and other basic needs will have high importance and therefore greater need for LEP access.
    4. Your available resources and costs.
  4. Find competent interpreters.
    1. A competent interpreter: is able to communicate effectively in both English and the other language, knows specialized terms in both languages, will follow confidentiality rules to the same extent as employees, will understand their role as interpreter.
    2. Options: Hire bilingual staff, hire interpreters on a contract basis, use a language line telephone service, use volunteer interpreters (but must be competent), allow LEP person to use a friend or family member if they so choose (may not be appropriate in some situations such as where sensitive, confidential, or embarrassing information would be revealed).
  5. Translate vital documents.
    1. If a language group is frequently encountered (e.g.,Spanish in the Boise area), then vital and widely used documents must be translated.
      1. Examples of vital documents:  written notices of rights, hearing notices, notices of eviction, leases and tenant rules, applications for services, consent forms.
    2. Use a competent translator and ideally, have a second translator check the translation.
    3. Translation Safe Harbor = “strong evidence of compliance”:  If you provide written translations of vital documents for each language group that constitutes 5% or 1,000 (whichever is less) of the population of persons eligible for your services; and you provide oral interpretation free of cost for persons in a language group that is 5% of the population of persons eligible for your services but fewer than 50 people. 
  6. Develop an LEP Plan – an implementation plan to address the needs of LEP populations identified in the four-factor analysis.  Either a written plan, or some other way to document your strategy for providing LEP access.
  7. Make sure your staff receive training on your LEP policies and on how to work with interpreters.
  8. Provide notice to LEP persons that LEP access is available:  signs, outreach, phone messages.
  9. Monitor and update your LEP Plan to assess changes in population, new vital documents, whether you are meeting LEP persons’ needs, and whether new staff have been adequately trained.


The work that provided the basis for this publication was supported by funding under a grant with the U.S. Department of Housing and Urban Development. The substance and findings of the work are dedicated to the public. The author and publisher are solely responsible for the accuracy of the statements and interpretations contained in this publication. Such interpretations do not necessarily reflect the views of the Federal Government.

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