EAST TENNESSEE DEVELOPMENT DISTRICT
POLICY AND PROCEDURES FOR COMMUNICATION WITH PERSONS WITH LIMITED ENGLISH PROFICIENCY
The East Tennessee Development District will take reasonable steps to ensure that persons with Limited English Proficiency (LEP) have meaningful access and an equal opportunity to participate in our services, activities, programs, and other benefits. The policy of the East Tennessee Development District is to ensure meaningful communication with LEP clients and their authorized representatives regarding access to programs and benefits offered or managed by the East Tennessee Development District, either directly or indirectly. The policy also provides for communication of information contained in vital documents, including but not limited to, program applications, employment application forms, financial and insurance benefit forms, and other applicable forms. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the person being served, and employees/clients 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 East Tennessee Development District will conduct a regular review of the language access needs of our patient population, as well as update and monitor the implementation of this policy and these procedures, as necessary.
- IDENTIFYING LEP PERSONS AND THEIR LANGUAGE
The East Tennessee Development District will promptly identify the language and communication needs of the LEP person. If necessary, staff will use a language identification card (or “I speak cards,” available online at www.lep.gov) or posters to determine the language. In addition, when records are kept of past interactions with patients (clients/residents) or family members, the language used to communicate with the LEP person will be included as part of the record.
- OBTAINING A QUALIFIED INTEPRETER
The Executive Director and/or the Deputy Director of the East Tennessee Development District are 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.
ASTA-USA Language Interpreting, Inc. has agreed to provide qualified interpreter services. ASTA-USA’s telephone number is (866) 466-1860 and the hours of availability are Monday – Friday, 8:00 am – 4:30 pm.
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 and other clients/patients/residents will not be used to interpret, in order to ensure confidentiality of information and accurate communication.
- PROVIDING WRITTEN TRANSLATIONS
(a) When translation of vital documents is needed, the Est Tennessee Development District will submit documents for translation into frequently encountered languages to the Executive Director or the Deputy Director. Original documents being submitted for translation will be in final, approved form with updated and accurate pertinent information.
(b) The East Tennessee Development District 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 East Tennessee Development District will set benchmarks for translation of vital documents into additional languages over time.
- PROVIDING NOTICE TO LEP PERSONS
The East Tennessee Development District 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 at points of entry and other common areas. Notification will also be provided through one or more of the following: outreach documents and website information.
- MONITORING LANGUAGE NEEDS AND IMPLEMENTATION
On an ongoing basis, the East Tennessee Development District will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, the East Tennessee Development District will regularly assess the efficacy of these procedures, including but not limited to mechanisms for securing interpreter services, equipment used for the delivery of language assistance, complaints filed by LEP persons, feedback from clients and community organizations, etc..
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