Factor #3 in Title VI Compliance: Availability and Cost of Resources

Availability and Cost of Resources

Any agency, regardless of size of staff or budget, that meets the definition as a federal assistance recipient, is required to comply with Title VI, part of which entails providing language services to LEP (Limited English Proficient) individuals.

Obviously, however, a small agency that has limited staff and resources probably will not be able to achieve the same level and type of language services as could a larger agency.

For example, a smaller agency may not be able to afford to attract and hire qualified bilingual professionals in each department, whereas a larger agency may actually be able to have an entire Hispanic Outreach Program, complete with full time interpreters, outreach workers, and an extensive library of Spanish-language materials.

The Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition (Volume 67, Number 117), prepared by the Department of Justice, gives some suggestions on how to reduce costs associated with providing language assistance services.

It says, “Resource and cost issues […] can often be reduced by technological advances; the sharing of language assistance materials and services among and between recipients, advocacy groups, and Federal grant agencies; and reasonable business practices.

Where appropriate,  training bilingual staff to act as interpreters and translators,  information sharing through industry groups, telephonic and video conferencing interpretation services, pooling resources and  standardizing documents to reduce translation needs, using qualified  translators and interpreters to ensure that documents need not be ‘fixed’ later and that inaccurate interpretations do not cause delay or other costs, centralizing interpreter and translator services to achieve economies of scale, or the formalized use of qualified community volunteers, for example, may help reduce costs.

Recipients should carefully explore the most cost-effective means of delivering competent and accurate language services before limiting services due to resource concerns. Large entities and those entities serving a significant number or proportion of LEP persons should ensure that their resource limitations are well-substantiated before using this factor as a reason to limit language assistance.”

Therefore, it is in the best interest of agencies and organizations that are covered by Title VI to make take reasonable steps towards complying with Title VI before deciding that a lack of financial commitment to the cause “exempts” them from compliance.

We can help your agency determine language assistance needs in your community, and help develop and appropriate and responsive language assistance plan.