National Origin is a protected class under Federal Fair Housing Laws, and this includes individuals with limited English proficiency (LEP). In fact, as part of their duties to affirmatively further fair housing, PHAs are required to take steps toward making their programs and services accessible to this group through the development of a language assistance plan. Here are some steps your agency can take to prepare and implement strategies for working with LEP persons.
Tip #1: Identify the languages spoken by the families you serve or could potentially serve.
Look at your past interactions with LEP individuals. What types of services were requested by those individuals, and what types of services did your PHA provide? This kind of historical data can be a great starting point for your analysis.
When looking at past interactions, another important question is whether there are groups in your community who may not be applying for housing because of perceived or real language barriers. In other words, are there people in your community who are not applying for your program simply because they're LEP?
Executive Order 13166 requires federal agencies to assess and
address the needs of otherwise eligible persons seeking access
to federally conducted programs who cannot fully or equally
participate in those programs due to limited English proficiency.
Examining different data sources can help your agency determine the groups in your community whose lack of English proficiency presents barriers to housing. Consult quantifiable data sources like census information, your local school system, faith-based organizations, legal aid organizations, other community organizations, or your state or local government to identify the languages that may be spoken in your community. When consulting the data, you aren't just looking to see whether people in your jurisdiction speak other languages, but also whether there is a lack of English proficiency among the families you serve or may serve.
Keep in mind that just because there's a high percentage of people in your community who speak a particular language other than English, it doesn't necessarily mean that those individuals are your largest LEP population; those individuals may be very proficient English speakers. Instead, look at the data to identify the percentage of people in your area who speak or understand English less than well. This may be an entirely different population than you suspected.
Next: How to meet your community’s LEP needs: Tip #2
Becky Gligo has been a trainer and consultant at Nan McKay and Associates since 2008. She trains hundreds of housing authority staff each year, both in open enrollment and onsite trainings. Ms. Gligo is one of NMA's primary fair housing experts.
Do you have concerns about whether or not your agency is compliant with federal fair housing law? Nan McKay and Associates can help. Email sales@nanmckay.com for more information.
