Accessibility

Serving Persons with Limited English Proficiency

The City of Inver Grove Heights has established the following Language Access Plan (LAP) to ensure that individuals with limited English proficiency (LEP) may access the resources, programs and services provided by the City.

An "LEP individual" is defined as "an individual who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English."

The purpose of this plan is to establish strategies for interacting with and providing services to LEP individuals in order to ensure equity and inclusion across the City's programs and services. Such strategies shall be implemented at no cost to LEP individuals.

Identification & Assessment of LEP Communities

Data from the American Community Survey, available on the website of the U.S. Census Bureau, is used to identify the prevalence of LEP individuals in the community. This data shows that 86.8% of Inver Grove Heights residents speak only English and another 7.8% of residents who speak another language at home also speak English "very well." Of the remaining residents, approximately 2.9% of the City's population speaks Spanish at home and does not speak English well, suggesting they may need language services in order to access City programs, services and information. No other language is spoken at home, where English is not also spoken well, by 1% or more of the City's households.

As the community evolves over time, the City will continue to monitor shifts in population demographics through biennial assessments to ensure that we are adequately tracking LEP representation in our jurisdiction. We will also work to identify LEP individuals in everyday encounters with the public by:

• Utilizing LEP strategies in situations where efforts to communicate in English are unsuccessful
• Responding to individual requests for language assistance services
• Using "l Speak" language identification cards or posters

Language Assistance Services

LEP individuals may interact with the City and its employees, volunteers and contractors in a number of ways including:

• By calling, writing or visiting city buildings and facilities
• In public meetings and public hearings
• At community events and outreach programs
• When seeking or receiving emergency services from the City's Police and Fire Departments
• When participating in recreational programming or accessing the amenities at the Veterans' Memorial Community Center
• Through written materials and print publications, as well as the City's website and social media accounts.

Efforts to determine the extent of language assistance services warranted, identified that no language met the 1,000 residents or 5% of population threshold, however Spanish came close to the 1,000 resident threshold. Due to the very small percentage of LEP individuals speaking any one language and the variety of possible encounters or settings where LEP individual may interact with City departments, most language assistance services will be provided on an "as requested" basis.

Oral Language Assistance

Oral language assistance may be necessitated by encounters with LEP individuals either over the phone, in person, or at public hearings. When one of these encounters occurs, staff members will carry out the following protocol:

• For communication over the phone:
  The staff member will first make an effort to identify the primary language of the individual. If that
  staff member is approved as bilingual in the individual's primary language, then that staff member may assist the LEP individual directly. If the staff member has not been approved as bilingual in that language, then the Language Line may be used to communicate with the LEP individual.
• For communication in person:
  The staff member will first make an effort to identify the primary language of the individual, using an "l Speak" language card if necessary. If that staff member is approved as bilingual in the individual's primary language, then that staff member may assist the LEP individual directly. If the staff member has not been approved as bilingual in that language, then the Language Line may be used to communicate with the LEP individual.
• For public meetings and hearings:
  An approved interpreter will be provided upon advance request. A phone number will be provided on the written notice of the public meeting or hearing for LEP individuals to call and request an interpreter.

Written Language Assistance

Written language assistance may be necessitated for a number of documents, notices, advertisements, forms, etc. "Vital documents" will be translated proactively and made accessible to the LEP communities previously identified. Documents will be classified as "vital" by balancing the frequency of contact that LEP individuals have with the document, the importance and potential consequences associated with the document, and organizational resources. Documents not considered vital will be available for oral or written translation upon request. Translated documents will also be accompanied with the following disclaimer:

'We are providing the translation to you as a convenience to assist in your understanding of your rights and obligations. The English language version of this document is the official, legal, controlling document. This translated document is not an official document."

Guidelines for Interpreters & Translators

While no forma! certification is required for interpreters, translators, or staff members, individuals providing interpretation or translation services must:

• Be proficient in and able to communicate information accurately in both English and the other applicable language
• Understand agency-specific terminology
• Act in an ethical manner and ensure confidentiality and impartiality in their role as an interpreter/translator

LEP individuals may bring another individual to provide interpretation who has not been approved for formal interpretation services by the agency. During these encounters, staff will:

• Inform the LEP individual that free language assistance services are provided
• Use a formal interpreter instead of the informal interpreter, especially if the subject matter of the encounter may be prone to conflicts of interest
• Avoid the use of minors as informal interpreters unless there is an immediate need.

When working with an interpreter, formal or informal, City staff should:

• Explain to the interpreter the purpose of the communication and the information to be conveyed
• Briefly explain to the interpreter technical terms that may come up during the communication
• Avoid the use of acronyms, double negatives, and contractions
• Speak in short sentences that contain one idea at a time
• Talk to the applicant and not to the interpreter
• Enunciate clearly and wait for the interpreter to finish before continuing to the next idea.

Providing Notice of Language Assistance Services

To ensure that members of LEP communities are aware of the free language assistance services available, the following marketing and outreach steps will be taken:

• Provide notification of service availability with materials such as meeting agendas, mailed notices, and programming brochures, and via signage at primary points of public contact.
• Provide "l Speak" language identification cards to front office staff.

Training Staff on Nondiscrimination & LEP Policies & Services

City staff will receive ongoing training on the importance of nondiscrimination and providing meaningful information and services to LEP communities. After completion of the training, staff should understand:

• The nondiscrimination laws covered under this policy
• The employee's obligation to provide meaningful access to information and services to LEP individuals
• The protocol for handling various encounters with LEP individuals, as established by this plan
• How to access translated materials and interpretation services for provision to LEP individuals.

Applicable Laws

This Nondiscrimination Policy and Language Access Plan shall follow and remain in compliance with the following nondiscrimination laws:

• Race, color or national origin: Title VI of the Civil Rights Act of 1964;
• Disability: Section 504 of the Rehabilitation Act of 1973;
• Sex in education programs or activities: Title IX of the Education Amendments Act of 1972;
• Age: Age Discrimination Act of 1975
• Religion and Social Services Programs: U.S. Department of Homeland Security regulation 6 C.F.R. Part 19.

Monitoring, Evaluating, & Updating this Plan

The City Administrator will monitor and evaluate the effectiveness of this plan and make updates accordingly. To do this, he/she will make use of the following strategies:

• Seek staff input on the frequency of interactions with LEP individuals and the effectiveness of existing language assistance services
• Solicit feedback from community-based organizations and other stakeholders
• Keep current on community demographics
• Monitor the agency's response rate to suggestions or requests by LEP individuals
• Maintain a record of available services for LEP individuals and the frequency of their use
• Maintain a record of funds and staff time spent on language assistance services.
• Observe and evaluate agency interactions with LEP individuals

Adopted February 12, 2024