Policy and Procedures for Communications with Persons with Limited English Proficiency
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Document Number: EOP--002
Revision #: 2.0
Document Owner: VP of Facilities and Infrastructure
Date Last Updated: 03/21/2018
Primary Author: VP of Facilities and Infrastructure
Status: Approved
Date Originally Created: 10/31/2011
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General Description
Description:
Cumberland University will take reasonable steps to ensure that persons with Limited English Proficiency (LEP) have meaningful access and an equal opportunity to participate in its services, activities, programs and other benefits.
Purpose:
Cumberland University will take reasonable steps to ensure that persons with Limited English Proficiency (LEP) have meaningful access and an equal opportunity to participate in its services, activities, programs and other benefits. The policy of the University is to ensure meaningful communication with LEP students/families and their authorized representatives involving their student-related issues. The policy also provides for communication of information contained in vital documents, including but not limited to, waivers of rights, consent forms, financial forms, etc. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the person being served, and students and their families will be informed of the availability of such assistance free of charge.
Language assistance will be provided through use of competent bilingual staff, staff interpreters, contracts or formal arrangements with local organizations providing interpretation or translation services, or technology and telephonic interpretation services. All staff will be provided notice of this policy and procedure, and staff that may have direct contact with LEP individuals will be trained in effective communication techniques, including the effective use of an interpreter.
The University will conduct a regular review of the language access needs of its student population, as well as update and monitor the implementation of this policy and these procedures, as necessary.
Scope:
All Departments and/or Department heads, Students, Staff, Faculty, Administration, Board of Trust
Responsibility:
Administration
All Departments and/or Department heads
Board of Trust
Faculty
Staff
Students
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Requirements
Approvals:
This policy must be in compliance with federal mandates under Title VI.
Relevant Knowledge:
Federal statutes
Current University policy
Local statutes
Standard company policies
Standards of good practice
State statutes
Terms and Definitions:
Additional training
Corrective Action
Loss of privilege, general
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Policy Provisions
1. Identifying LEP persons and their language
Cumberland University will promptly identify the language and communication needs of a LEP person. In addition, when records are kept of past interactions with LEP students or family members, the language used to communicate with such person will be included as part of the record.
2. Obtaining a qualified interpreter
Cumberland University's , who also serves at the University's Title VI and Title IX Coordinator, is responsible for:
a. Maintaining an accurate and current list showing the name, language, phone number and hours of availability of bilingual staff;
b. Contacting the appropriate bilingual staff member to interpret, in the event that an interpreter is needed, if an employee who speaks the needed language is available and is qualified to interpret;
c. Obtaining an outside interpreter if a bilingual staff or staff interpreter is not available or does not speak the needed language.
Some LEP persons may prefer or request to use a family member or friend as an interpreter. However, family members or friends of the LEP person will not be used as interpreters unless specifically requested by that individual and after the LEP person has understood that an offer of an interpreter at no charge to the person has been made by the facility. Such an offer and the response will be documented in the person’s file. If the LEP person chooses to use a family member or friend as an interpreter, issues of competency of interpretation, confidentiality, privacy, and conflict of interest will be considered. If the family member or friend is not competent or appropriate for any of these reasons, competent interpreter services will be provided to the LEP person.
Children will not be used to interpret, in order to ensure confidentiality of information and accurate communication.
3. Providing written translations
a. When translation of vital documents is needed, each unit in the University will submit documents for translation into frequently-encountered languages to the appropriate staff person. Original documents being submitted for translation will be in final, approved form with updated and accurate legal and medical information.
b. Facilities will provide translation of other written materials, if needed, as well as written notice of the availability of translation, free of charge, for LEP individuals.
c. The University will set benchmarks for translation of vital documents into additional languages over time.
4. Providing notice to LEP persons
The University will inform LEP persons of the availability of language assistance, free of charge, by providing written notice in languages LEP persons will understand. At a minimum, notices and signs will be posted and provided in a specific point of entry, Memorial Hall (administration building). Notification will also be provided through one or more of the following: outreach documents, telephone voice mail menus, newspapers, campus newsletters, campus-based organizations, and on the University website.
5. Monitoring language needs and implementation
On an ongoing basis, the University will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, the University will regularly assess the efficacy of these procedures, including but not limited to mechanisms for securing interpreter services, equipment for the delivery of language assistance, complaints filed by LEP persons, feedback from students and community organizations, etc.
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Performance Evaluation
Desired Outcome:
Policies and procedures will insure compliance with Title VI mandates
Performance Metrics:
Compliance with standard policy and procedure
Customer Satisfaction Rating
Consequences:
Further training
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Subject Experts
The following may be consulted for additional information.
VP of Facilities and Infrastructure