PEP Housing (PEP) 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 housing and services provided. As defined in 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 people that assistance is available.
To prepare this plan, PEP used four-factor LEP analysis which considers the following factors:
1. The number or proportion of LEP persons eligible to be served or likely to be encountered by PEP.
2. The frequency with which LEP persons encounter PEP programs, activities or services.
3. The nature and importance of the program, activities or services provided by PEP to the LEP population.
4. The resources available to PEP for LEP outreach, as well as the costs associated with that outreach.
Meaningful Access: Four-Factor Analysis
The number or proportion of LEP persons eligible to be served or likely to be encountered by PEP.
PEP provides affordable senior housing in four California counties (Sonoma, Solano, Mendocino, Butte). PEP staff reviewed the 2020 U.S. Census Report and compiled the following statistics to identify the number or proportion of LEP persons eligible to be served or likely to be encountered by PEP.
It was determined that 357,811 persons in the combined service areas (28.7%) speak a language other than English. Of those persons, 129,381 (36.2%) speak English less than “very well”. Of those persons with limited English proficiency, 102,847 (79.5%) Spanish speaking persons speak English less than “very well”. There were 50,895 (39.3%) persons of other Indo-European languages who spoke English less than “very well”, and 44,070 (38.8%) of Asian and Pacific Islanders who spoke English less than “very well”.
2. The frequency with which LEP persons encounter PEP programs, activities or services.
PEP reviewed the frequence with which staff have, or could have, contact with LEP persons. This includes documenting phone and email inquiries and office visits. To date, the most frequent contact between LEP persons is with property managers, resident service coordinators, maintenance, and corporate office staff.
3. The nature and importance of the program, activity, or service provided by PEP to the LEP population.
PEP provides essential services in the form of affordable senior housing across four counties in California (Sonoma, Solano, Mendocino, and Butte). The nature of PEP’s program is crucial to supporting vulnerable populations, including seniors who may have limited English proficiency (LEP). Given that approximately 36.2% of those who speak a language other than English in these areas report speaking English less than “very well,” PEP’s services are likely to be significant to LEP individuals.
The housing provided by PEP helps ensure that seniors, including those from LEP populations, have access to stable, affordable living environments, which can be particularly important as this demographic may face additional barriers, such as limited access to information and resources due to language challenges. By offering housing across four counties with notable LEP populations, PEP plays a critical role in fostering inclusivity and support for these communities, ensuring they have the necessary resources to age in place with dignity and security.
4. The resources available to PEP for LEP outreach, as well as the costs associated with that resource.
PEP’s outreach to Limited English Proficiency (LEP) populations in the four counties (Sonoma, Solano, Mendocino, and Butte) requires thoughtful allocation of resources, both in terms of staff and materials. Resources for LEP outreach may include:
1. Bilingual Staff and Volunteers:
PEP can recruit or train bilingual staff and volunteers, particularly in languages most spoken by LEP individuals in the service areas, such as Spanish and certain Asian and Pacific Islander languages. Having staff members who can effectively communicate in these languages is a key resource for reaching and serving LEP populations.
-Cost Consideration: Hiring or training bilingual staff comes with additional salary costs or training program expenses. However, it enhances communication and improves service delivery to LEP individuals.
2. Translation and Interpretation Services:
PEP may utilize professional translation services for important documents, such as housing applications, legal forms, and informational materials, ensuring that LEP individuals have access to critical information. Interpretation services, either in-person or via telephone, may also be used to facilitate interactions with LEP seniors.
-Cost Consideration: Translation and interpretation services can be expensive, especially when dealing with multiple languages. Document translation costs can range from $0.10 to $0.30 per word, while interpretation services may cost $40–$150 per hour.
3. Culturally and Linguistically Appropriate Outreach Materials:
PEP can develop outreach materials—brochures, flyers, and advertisements—in the primary languages spoken by LEP individuals (e.g., Spanish and other Indo-European and Asian languages). These materials can be distributed through community organizations, healthcare providers, and cultural centers serving LEP populations.
– Cost Consideration: Developing and printing multilingual outreach materials will incur design and printing costs, as well as distribution expenses. Partnering with community organizations to distribute materials can help lower outreach costs.
4. Partnerships with Local Organizations:
PEP can partner with local community-based organizations (CBOs) that specialize in serving LEP communities. These partnerships can help PEP engage with LEP populations more effectively, as CBOs often have established trust within these communities.
– Cost Consideration: While partnerships may not directly cost PEP, they may require resource-sharing agreements, event participation, or co-hosting of workshops, which can involve staff time and coordination.
5. Technology-Based Solutions:
Utilizing technology, such as multilingual websites and online portals, can be a cost-effective way to reach LEP populations. Providing key information in multiple languages online ensures broad access to PEP’s resources and services.
– Cost Consideration: Developing and maintaining a multilingual website may have upfront development costs, but it could prove to be a long-term cost-effective resource for engaging with LEP individuals.
Summary of Costs:
– Bilingual staff/volunteers: Salary/training costs
– Translation and interpretation services: Variable, dependent on volume of
content and interaction frequency
– Outreach materials: Design, printing, and distribution costs
– Partnerships with CBOs: Potentially cost-effective, with shared resources
– Technology solutions: Website development and maintenance costs
Given the significant LEP population in PEP’s service areas, investment in these resources is crucial for ensuring that LEP individuals are adequately served.
Language Assistance
A person who does not speak English as their primary language and who has 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 PEP programs and activities. Language assistance can include interpretation, which means oral or spoken transfer of a message from one language to another language and/or translation, which means the written transfer of a message from one language into another language. PEP will determine when interpretation and/or translation are needed and are reasonable.
How PEP staff may identify an LEP person who needs language assistance:
• Examine records to see if requests for language assistance have been received in the past, either in person or over the phone, to determine whether language assistance might be needed in the future.
• Have Language Identification (“I Speak”) Flashcards available at each property and the corporate office and easily accessible to all staff members as needed.
• Periodically interview property managers, resident service coordinators, maintenance, corporate office and other front-line staff on their experience concerning any contacts with LEP persons during the previous year.
Language Assistance Measures
There are several language assistance measures available to LEP persons, including both oral and written language services. There are also various ways in which PEP staff may respond to LEP persons, whether in person or, by telephone, or in writing.
• PEP will provide an interpreter to an LEP person if they request language assistance or if it is evident that such assistance is needed.
• If an LEP person asks for language assistance and PEP determines that language assistance is necessary to provide meaningful access, reasonable efforts will be made to provide free language assistance.
• When an interpreter is needed, in person or on the telephone, staff will attempt to determine what language is required and then make available interpretation services for the LEP person.
• Bilingual PEP staff will provide language services to LEP persons upon request and if available. PEP will take reasonable steps to ensure that staff provide interpretive services at a level of fluency, comprehension and confidentiality appropriate to the specific nature, type, and purpose of the information at issue.
• An LEP person may use an informal interpreter of their choosing and at their own expense, either in place of or as a supplement to the language assistance offered by PEP. Informal interpreters may include family members, friends, legal guardians, service representatives, or advocates of the LEP person.
• PEP will periodically assess client needs for language assistance based on requests for interpreters and/or translation, as well as the literacy skills of the clients.
Staff Training
Staff training will be included with onboarding and annually for all PEP staff:
• Information on the Title VI Policy and LEP responsibilities.
• Description of the language assistance services offered to the public.
• Use of the Language Identification (“I Speak”) Flashcards.
• Documentation of language assistance requests.
• How to handle a potential Title VI/LEP complaint.
All contractors or subcontractors performing work for PEP will be required to follow the Title VI/LEP guidelines.
Translation of Documents
PEP has carefully considered the costs and benefits of translating documents for potential LEP groups, particularly Spanish-speaking individuals. Given the expenses associated with translating documents, the potential for frequent updates, and other relevant factors, PEP has determined that, at this time, it is not necessary to translate documents on a routine basis.
When the need for LEP services occurs, PEP will do the following:
• When staff prepares documents or schedules a meeting where LEP individuals are expected to be part of the target audience, materials such as meeting notices, flyers, agendas, and relevant documents will offer key documents in Spanish, based on the identified LEP population.
• Key documents, such as pre-applications, applications, leases, and property-related forms, will be offered in Spanish and other languages if a specific, concentrated LEP population is identified and requests for translated documents are made.
PEP remains committed to ensuring equitable access to services and will assess translation needs as the demographics of the service areas evolve.
Monitoring and Updating the LEP Plan
PEP will update the LEP Plan as required. At a minimum, the plan will be reviewed and updated when data from the upcoming U.S. Census is made available, or when higher concentrations of LEP individuals are present in the PEP service area. Updates will include the following:
• The number of documented LEP person contacts encountered annually.
• How the needs of LEP people have been addressed.
• Determination whether local language assistance programs have been effective and sufficient to meet the need.
• Determine whether PEP’s financial resources are sufficient to fund language assistance resources needed.
• Determine whether PEP fully complies with the goal of this LEP plan.
• Determine whether complaints have been received concerning PEP’s failure to meet the needs of LEP individuals.
• Maintain a Title VI complaint log, including LEP to determine issues and basis of complaints.
Dissemination of the PEP LEP Plan
PEP’s Title VI Policy and LEP Plan are made available on the company’s website at www.pephousing.org. Any person or agency may request a copy of the LEP plan via telephone, email, fax, mail, or in person and shall be provided a copy of the plan at no cost. LEP individuals may request a copy of the plan in alternative languages which will be provided, if feasible.
Questions concerning the LEP Plan may be submitted to PEP Housing at:
PEP Housing
625 Acacia Way
Santa Rosa, CA 95409
Phone: (707) 762-2336
Fax: (707) 981-7515
Email : pep@pephousing.og
www.pephousing.org