Policy 521: Policy for Providing Meaningful Communication with Persons with Limited English Proficiency

Category: Personnel Policies
Subcategory: General
Covered Individuals: Staff, Faculty, and Students
Responsible Executive: Vice President for Operational Strategy and Special Advisor
Policy Custodian: Office of Equity, Executive Director
Last Revised: 2022/04/10
Previous USU Policy Number: N/A
Download the PDF File for Policy 521

521.1 PURPOSE AND SCOPE

To ensure that persons with Limited English Proficiency have meaningful access and an equal opportunity to participate in our services, activities, programs and other benefits.

521.2 POLICY

The policy of Utah State University (hereinafter USU) is to ensure meaningful communication with Limited English Proficiency (hereinafter LEP) students, staff, faculty, and their authorized representatives involving their academic and employment pursuits. This policy also provides for communication of information contained in vital documents, including but not limited to, employment records, financial and insurance benefit forms, and academic records. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the person being served. Additionally, employees, staff, and faculty 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 students, staff and faculty of USU 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.

USU will conduct a regular review of the language access needs of our population, as well as update and monitor the implementation of this policy and these procedures, as necessary.

521.3 RESPONSIBILITIES

3.1 Identifying LEP Persons and their Language

The Office of Equity 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 students, staff, or faculty members, the language used to communicate with the LEP person will be included as part of the record.

3.2 Obtaining a Qualified Interpreter

The Office of Equity 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 us 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 USU. 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.

3.3 Providing Written Translations

(a) When translation of vital documents is needed, each unit will submit documents for translation into frequently encountered languages to the Office of Equity. Original documents being submitted for translation will be in final, approved form with updated and accurate information.

(b) The Office of Equity 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 Office of Equity will set benchmarks for translation of vital documents into additional languages over time.

3.4 Providing Notice to LEP Persons

The Office of Equity will inform LEP persons of the availability of language assistance, free of charge, by providing written notice in languages LEP persons will understand. Notification will also be provided through outreach documents.

3.5 Monitoring Language Needs and Implementation

On an ongoing basis, the Office of Equity will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, the Office of Equity 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 students, staff, and faculty.

521.4 REFERENCES

RESOURCES

Notice of Non-Discrimination

In its programs and activities, including in admissions and employment, Utah State University does not discriminate or tolerate discrimination, including harassment, based on race, color, religion, sex, national origin, age, genetic information, sexual orientation, gender identity or expression, disability, status as a protected veteran, or any other status protected by University policy, Title IX, or any other federal, state, or local law. The following individuals have been designated to handle inquiries regarding the application of Title IX and its implementing regulations and/or USU’s non-discrimination policies.

Executive Director of the Office of Equity
Matthew Pinner
Matthew.pinner@usu.edu
Distance Education Room 401
Logan, UT 84322
435-797-1266

Title IX Coordinator
Cody Carmichael
Cody.carmichael@usu.edu
Distance Education Room 404
Logan, UT 84322
435-797-1266

For further information regarding non-discrimination, please visit https://equity.usu.edu/, or contact:

U.S. Department of Education
Office of Assistant Secretary for Civil Rights
800-421-3481
OCR@ed.gov

U.S. Department of Education
Denver Regional Office
303-844-5695
OCR.Denver@ed.gov

POLICY HISTORY

Original issue date: 2024/04/10
Last review date: N/A
Next scheduled review date: 2027/04/10
Previous revision dates: N/A