LIMITED ENGLISH PROFICIENCY PLAN
UNITED COMMUNITY ACTION PROGRAM, INC.
CIMARRON PUBLIC TRANSIT SYSTEM
TITLE VI COORDINATOR:
501 SIXTH STREET, PAWNEE, OK 74058
November 13, 2012
Revised November 2016
This Limited English Proficiency Plan has been prepared to address Cimarron Public Transit’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English proficiency language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq, and its implementing regulations, which state that no person shall be subjected to discrimination on the basis of race, color or national origin.
Executive Order 13166, titled Improving Access to Services for Persons with limited English Proficiency, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all state and local agencies which receive federal funds, including all Cimarron Public Transit.
Cimarron Public Transit System has developed this Limited English Proficiency Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency (LEP) who wish to access services provided. As defined Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write or understand English. This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available.
In order to prepare this plan, Cimarron Public Transit System used the four-factor LEP analysis which considers the following factors:
MEANINGFUL ACCESS: FOUR-FACTOR ANALYSIS
Cimarron Public Transit staff reviewed the 2000 U.S. Census Report and determined that 3,544 persons, or 2% of population in Cimarron Public Transit service area speak English “less than very well”.
Cimarron Public Transit staff reviewed the frequency with which the board, office staff and drivers have, or could have contact with LEP persons. This includes phone inquiries or office visits. To date, Cimarron Public Transit has had no requests for interpreters and no requests for translated program documents. The board, office staff and drivers have very little contact with LEP persons. Those they do come in contact with have a family member or friend to assist with translation.
There is no large geographic concentration of any type of LEP individuals in the service area for Cimarron Public Transit. The overwhelming majority of the population speak only English. As a result, there are no social, service, professional and leadership organizations within the Cimarron Public Transit service area that focus on outreach to LEP individuals, that the agency is aware of. Cimarron Public Transit board, office staff and drivers are most likely to encounter LEP individuals through transportation rides, office visits, phone conversations and attendance at board or public meetings.
Cimarron Public Transit reviewed its available resources and determined that there are no local citizens available to provide voluntary Spanish translation, however, a part time, bi-lingual driver is available to assist with Spanish translation and a part time, bi-lingual driver is available to assist with Russian translation. It was determined that The Ridership Policy, Title VI Notice to the Public and WorkRide Form were most needed to be translated in Spanish. Each site has a copy available for use. Spanish Translation cards were printed for each transit staff member to assist in communicating with someone speaking Spanish. The website and brochures have a notice in Spanish if information is needed in another format. Google translate is another option to provide translation assistance if other needs should arise.
A person who does not speak English as their primary language and who has a limited ability to read, write, speak or understand English may be a Limited English proficient person and may be entitled to language assistance with respect to Cimarron Public Transit services. Language assistance can include interpretation, which means oral or spoken transfer of a message from one language into another language and/or translation, which means the written transfer of a message from one language into another language.
How Cimarron Public Transit staff may identify an LEP person who needs language assistance:
●Cimarron Public Transit staff can be provided “I Speak” cards to assist in identifying the language interpretation needed, if the occasion arises.
●Cimarron Public Transit staff will be informally surveyed periodically on their experience concerning contacts with LEP persons during the previous year.
●When Cimarron Public Transit sponsors an informational meeting or event, an advanced public notice of the event will likely be published in local newspapers, including an opportunity to request an accommodation related to offering a translator (LEP) or interpreter (sign language for hearing impaired individuals). Additionally, a staff person may greet participants as they arrive. By informally engaging participants in conversation it is possible to gauge each attendee’s ability to speak and understand English. Although translation may not be able to be provided at the event it will help identify the need for future events.
Language Assistance Measures
Although there is a very low percentage of LEP individuals, that is, persons who speak English “not well” or “not at all”, in Cimarron Public Transit System’s service area, it will strive to offer the following measures:
●Volunteer interpreters for the Spanish language will be contacted for availability within a reasonable time period.
●Attempts will be made for language interpretation for all other languages through Google Translate or telephone interpretation services, as needed.
The following training will be provided to all staff:
●Information on the Title VI Policy and LEP responsibilities.
●Description of language assistance services offered to the public.
●Use of Spanish translation cards.
●Documentation of language assistance requests.
●How to handle a potential Title VI/LEP complaint.
TRANSLATION OF DOCUMENTS
Cimarron Public Transit weighed the cost and benefits of translating documents for potential LEP groups. Considering the expense of translating the documents, the likelihood of frequent changes in documents and other relevant factors, at this time the Ridership Policy and Work Ride Form are the only items translated into Spanish.
Due to the very small local LEP population, Cimarron Public Transit does not have a formal outreach procedure in place. Translation resources are limited in this region. However, when and if the need arises for LEP outreach, Cimarron Public Transit will consider available options.
When staff prepares a document, or schedules a meeting, for which the target audience is expected to include LEP individuals, documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population.
Cimarron Public Transit will update the LEP Plan as required. At a minimum, the plan will be reviewed and updated when data from the new Census is available, or when it is clear that higher concentrations of LEP individuals are present in Cimarron Public Transit service area. Updates will consider the following:
●The number of documented LEP person contacts encountered annually.
●How the needs of LEP persons have been addressed.
●Determination of the current LEP population in the service area.
●Determination as to whether the need for translation services has changed.
●Determine whether Cimarron Public Transit’s financial resources are sufficient to fund language assistance resources needed.
●Determine whether Cimarron Public Transit fully complies with the goals of this LEP Plan.
●Determine whether complaints have been received concerning the agency’s failure to meet the needs of LEP individuals.
●Review any Title VI complaints, including LEP to determine issues and basis of complaints.
DISSEMINATION OF CIMARRON PUBLIC TRANSIT LEP PLAN
Title VI Notice to the Public is posted at each transit site and on the agency web site. The Spanish translation is posted below the English version. A phone number is provided if information is needed in another format. This is also printed on program brochures.