Tip #4: Develop and implement a language assistance plan based on a four-factor analysis.
The steps we've discussed up to this point comprise an analysis of the following four factors:
- The number or proportion of LEP persons eligible to be served
- The frequency with which these individuals come into contact with the program
- The nature and importance of the program, service, or activity to these individuals' lives
- The resources available to the PHA, and the costs
Collectively, this is referred to as a four-factor analysis, and it's the cornerstone of any successful language assistance plan.
Once you've conducted a four-factor analysis, developing a language assistance plan (LAP) should come easy. The four-factor analysis will give your agency a clearer picture of which services it will provide, and your LAP can be a guide to realistically implementing those services. The LAP will help ensure consistency in the way staff members work with LEP individuals and serve as a framework for how your agency documents these important efforts. The plan can also offer guidance to managers for budgeting and training decisions.
More information on developing language assistance plans can
be found at the HUD website. You may also want to review the
Federal Register notice spelling out relevant LEP guidance.
Once you've developed your LAP, you can move forward with implementation. While every housing authority should have an LAP, not every housing authority will need to implement it. The key is to have a plan on paper should the need for services arise. Your plan can take place over a period of time — HUD recognizes that financial constraints are real and that LEP implementation doesn't happen overnight.
In summary, here are the four basic steps that your agency can take in order to meet the needs of the LEP members of your community:
- Identify the languages spoken by the families you serve or could potentially serve.
- Take stock of your agency’s existing resources for LEP individuals.
- Determine the costs and availability of additional necessary language resources.
- Develop and implement a language assistance plan based on a four-factor analysis.
As a federally funded agency, you are responsible for making sure that individuals in your community with limited English proficiency have meaningful access to the programs and services you provide. When taken together, these steps will help your agency to develop a language assistance plan (LAP) that can effectively remove the barriers for this group of individuals, while at the same time keeping your agency in compliance with HUD LEP guidance.
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. Our resources for your PHA include consulting, a newly-updated video, and a training seminar, also newly updated.
