Plan for Providing Access to Benefits and Services for Individuals With Limited English Proficiency (LEP)
Updated August 2011
Background: Section 2 of Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency,” requires Federal agencies to develop and implement a plan for improving access to services and participation in federally conducted programs and activities for individuals with LEP (August 11, 2000). We submitted our original LEP plan to the Department of Justice (DOJ) on December 19, 2000.
On June 18, 2002, DOJ published regulations (67 FR 41455) that further defined requirements and established the four factors we consider when determining what constitutes reasonable steps to ensure meaningful access to LEP services. We applied the four-factor analysis to update our LEP plans in February 2003, September 2004, July 2008, and February 2010. The factors are:
- Number or proportion of individuals with LEP in the eligible service population;
- Frequency with which individuals with LEP come into contact with our program;
- Importance of the service our program provides; and
- Agency resources.
On February 17, 2011, Attorney General Eric Holder issued a memorandum that requested each Federal agency to conduct a self-assessment of LEP services, to update its plan to improve the language accessibility of its federally conducted programs and activities, and to take steps to implement the plan. DOJ also provided the “Language Access Assessment and Planning Tool for Federally Conducted and Federally Assisted Programs,” with additional guidance. Using this tool, we conducted a self-assessment of our LEP services and updated our plan.
Introduction: We administer programs that touch the lives of millions of people. Our efforts to improve the services we provide to increasing numbers of individuals with LEP predate Executive Order 13166. In February 1995, we chartered an LEP inter-component workgroup, which met on a regular basis and was responsible for planning and implementing our LEP activities. Since then, we have been proactive in implementing a comprehensive plan for increased access and services to individuals with LEP.
Vision Statement: We strive to deliver effective, efficient, and equitable service to the public, which includes providing access to our program and services, regardless of the ability to speak, read, or write English.
We continuously seek to improve and expand service delivery options available to individuals with LEP that allow them to communicate effectively with us in person, over the phone, in writing, or through electronic media and services.
Through our published LEP policy and procedures, we align our vision with the four strategic goals in our strategic plan, which are:
- Eliminate our hearings backlog and prevent its recurrence;
- Improve the speed and quality of our disability process;
- Improve our retiree and other core services; and
- Preserve the public’s trust in our programs.
Summary of Our LEP Policy: This plan conveys our LEP policy principles and will be available online to make the public and our employees aware of our LEP service delivery guidelines. Our policy ensures that individuals have access to our programs and services, regardless of their ability to communicate in English.
In 1995, we established our LEP policy principles. In July 2011, we conducted a self-assessment of our LEP services, as required by the Department of Justice. Based on our self-assessment we are taking the actions listed below, in accordance with the associated policy principles. Our personnel in Puerto Rico are bilingual in Spanish and English. Our policies for providing services and access to benefits for individuals in Puerto Rico with limited English and Spanish proficiency are consistent with this plan.
A. Resource Allocation:
- Policy: We will consider the needs of individuals with LEP in our policies and long-range business and strategic plans. Our resource allocations carefully consider the service needs of individuals with LEP, and we adopt service delivery initiatives that we can fully fund. As we deliver more services electronically, we will continue to assess the allocation of resources for LEP services.
- Action/Timeframe: Over the next 18 months, we will re-examine our business processes and create a strategy to ensure we fully consider the needs of individuals with LEP when funding and delivering services.
B. Service Delivery:
- Policy: Individuals with LEP access our services over the internet, via our national 800-Telephone service, via video service delivery, and through our network of approximately 1,500 local offices. Field offices develop strategies tailored to the needs of their communities to provide efficient and effective service. Through a variety of outreach activities, field offices also create and maintain cordial working relationships with diverse LEP populations.
We established policies and guidelines for identifying individuals with LEP and their preferred language. To project language preferences in order to determine service needs, we collect data to identify the number or proportion of individuals with LEP by service area and by factors such as age, language (written and spoken), and internet usage.
We collect data to enable us to project language preferences demographically and to identify the number or proportion of individuals with LEP by service area. We compile data, based on factors such as age, language, and internet usage, to identify LEP populations throughout the country, and to determine service needs. We collect data regarding our clients’ preferred written or spoken (communication) language at various service delivery contact points. We established policies and guidelines for identifying individuals with LEP and their preferred language.
In our field offices, our Visitor Intake Process (VIP), our self-service sign-in application, currently provides service only in English. We are currently working on enhancing the intake process to have English and Spanish options pre-set and display as default on the screen. We will offer an additional nine languages at the VIP kiosks.
- Action/Timeframe: Within the next year, we will re-examine our data collection methods to ensure that we accurately and fully capture LEP population data.
C. Bilingual/Bicultural Staffing:
- Policy: The most effective method for providing quality service to individuals with LEP is through bilingual/bicultural or multilingual public-contact employees. We identify bilingual/bicultural hiring needs through the continual assessment of changing language and cultural demographics.
Through hiring initiatives, we have increased the number of bilingual and multilingual employees serving the public to 9,590 in fiscal year (FY) 2010 (from 7,861 in FY 2007).
- Action/Timeframe: Over the next 18 months, we will re-examine our policy for utilizing bilingual/bicultural and multilingual employees and continue to examine our demographic data to ensure we meet the needs of individuals with LEP.
D. Qualified Interpreter Services:
- Policy: We use qualified office- based interpreters or telephone interpreters available through a national contract. If an individual with LEP prefers to use his or her own interpreter, such as a family member, friend, or third party, we will determine whether the interpreter meets our requirements. We generally will not permit a child under age 18 to serve as an interpreter (given the nature and complexities of our business processes). We do not require individuals who need language assistance to provide their own interpreters; rather, we provide an interpreter free of charge, to any individual requesting language assistance, or when it is evident that such assistance is necessary to ensure that the individual is not disadvantaged.
Our self-assessment confirmed that we have effective interpreter service policies. We have issued several recent reminders to staff about our policy to provide the public with interpreters free of charge.
- Action/Timeframe: Over the next year, we will re-examine our policies and standards to maintain and improve interpreter services.
E. Public Information:
- Policy: We recognize the value of public information to educate, improve access to our programs and services, address LEP concerns, promote program integrity, and build public confidence in the programs we administer.
To increase public awareness of our programs and services, we developed extensive outreach materials for the LEP population. We produce public information materials in 15 languages (other than English) accessible through a Multilanguage website (http://socialsecurity.gov/multilanguage/). We created a Spanish language website (http://www.segurosocial.gov), and we are expanding our online Spanish language web services, which include a Spanish Retirement Estimator (http://www.socialsecurity.gov/espanol/calculador/). We work with national and local culturally diverse community organizations as well as media and advocacy groups to help us share our public information resources with individuals with LEP. In addition, as noted in Section 2.A above, we compile data to identify LEP populations throughout the country to determine our marketing strategies.
- Action/Timeframe: Over the next year, we will re-examine our outreach and awareness strategy.
F. Written Communications:
- Policy: To facilitate access to our programs and to improve administrative effectiveness, we nationally produce written communications, such as public information materials, notices, and form letters, using the following criteria:
- Number of LEP beneficiaries/applicants;
- Number of field offices serving the LEP population;
- Literacy level in the non-English language;
- Anticipated demographic growth; and
- Action/Timeframe: As we develop new paths of communication, we will continue to consider ways to maintain and improve our service to the LEP population.
G. Listening to LEP Individuals:
- Policy: We periodically host focus group testing, and we have an online comment and suggestion system in place to respond to the public’s concerns and comments. We understand that better communication with individuals with LEP will help to
- Increase public understanding of our programs by providing information to individuals in a language they read, speak, and understand;
- Increase satisfaction with services provided by bilingual/bicultural staff;
- Improve program integrity; and
- Reduce the need for multiple contacts with individuals, by identifying the language preference at the initial contact.
- Action/Timeframe: Over the next year, we will examine the comment process to identify necessary enhancements.
H. Outreach to LEP Individuals:
- Policy: We promote our language access services to individuals with LEP through our national network of over 150 public affairs specialists (including bilingual public affairs specialists), bilingual/bicultural staff in our field offices, and our Office of Communications’ liaison activities with national and community-based organizations.
- Action/Timeframe: Over the next six months, we will confer with advocates for individuals with LEP and others interested in the needs of the LEP population to discuss effective ways to conduct LEP outreach.
- Policy: When evaluating existing and emerging technologies, we consider the needs of individuals with LEP, the resources available to meet those needs, and the effect of technology on the LEP population.
- Action/Timeframe: Over the next 18 months, we will re-examine our business processes to create a formal strategy that ensures we consider the needs of individuals with LEP when we procure, develop, or revise systems and technology.
- Policy: We provide training on basic LEP services, such as interpreter and translation policies, Multilanguage website, telephone interpreter services, etc., during new employee orientation training. We also provide reminder training in specific service areas via our Video-On-Demand and video broadcasts, and through policy reminders.
We provide training opportunities in cultural diversity for all employees in order to provide better service to LEP individuals. We also provide training to enhance the language skills of our bilingual employees.
- Action/Timeframe: In our self-assessment, we identified gaps in our LEP training. Over the next year, we will review and address the identified gaps in training.
K. Monitoring Our Services:
- Policy: We collect and track our LEP data on an ongoing basis at the national, regional, and local levels to determine the needs of the community and to allocate resources accordingly. We monitor our LEP policies and practices to ensure that they continue to be effective. To determine shifts in LEP demands, we also reevaluate the language groups that are most represented among the LEP population.
- Action/Timeframe: In our self-assessment, we identified several gaps in our LEP services monitoring activities. Over the next 18 months, we will develop a defined plan for monitoring, evaluating, and updating the language access program. Using internal and external (i.e., other agencies) best practices and our management information, we will identify procedures that align with our established quality performance process and procedures to ensure compliance with our LEP plan.
As stated in Section 1, we consider four factors when developing new programs and projects, including our electronic services. Our goal is to provide quality access to services for individuals with LEP.
Factor 1: Demography - Number or Proportion of LEP Individuals
The collection of preferred language data enhances our ability to make effective strategic staffing and resource allocation decisions. Beginning in 1999, we identified the demography of individuals with LEP by collecting and projecting language preferences for 27 languages. In June 2004, we expanded collection of preferred language data from 27 to 90 languages. Our ability to collect additional language preference data on the populations we serve allows us to strategically place bilingual staff consistent with the language demands.
We collect language preference information on individuals who apply for retirement, survivors, Social Security disability (Title II) and Supplemental Security Income (SSI or Title XVI).
In FY 2010, we projected that approximately 4.1 percent of claimants (2,921,131 claimants out of 71,282,198) would prefer interviews in a language other than English. Table 1 reflects the top five non-English language preferences by initial claims category
Table 1: FY 2010 Top Five Language Preferences Among Initial Claims
Title II – Old Age, Survivors, and Disability Insurance Benefits (Information includes the US Virgin Islands and Puerto Rico)
Title II Retirement & Survivors
Title II Disability Insurance
(Includes Cantonese & Mandarin)
Title XVI – Supplemental Security Income Benefits for the Aged, Blind, and Disabled
Title XVI Aged
Title XVI Blind & Disabled
Table 2 reflects the top five language non-English preferences by our other services for FY 2010.
Table 2: FY 2010 Top Five Language Preferences for Other Social Security Services
|Title II Post Entitlement||Title XVI Redeterminations & Limited Issues (Information does not include the US Virgin Islands and Puerto Rico)
||Social Security Number|
Factor 2: Frequency of Contact with the Program
Individuals with LEP contact us on a daily basis in person, by mail, phone, or internet, to apply for benefits, request other services, or ask questions about the programs we administer. As noted above in Factor 1, we collect language preference information on individuals who apply for benefits so that we can communicate with them in their preferred language.
Table 3 reflects the overall volume of initial claims that we received in FY 2010 and the number of claimants who preferred a language other than English
Factor 3: Nature and Importance of the Program
We provide income protection and other benefits for more than 162 million workers and their families. We administer the Old Age and Survivors Insurance program, Disability Insurance program, Supplemental Security Income programs, and Special Benefits for Certain World War II Veterans, and we assist Medicare beneficiaries in filing applications.
It is important to highlight the SSI program given its high volume of non-English language demand. For individuals with LEP who are eligible for SSI, we play a critical role in helping provide monthly payments and possible entitlement to medical and food assistance services.
Factor 4: Resources
We assist the LEP populations through our numerous public-contact offices, and we balance our resource needs through our central headquarters location and a network of 10 regional offices, including approximately:
- 1,300 field offices;
- 8 processing centers;
- 33 teleservice centers;
- 8 Social Security card centers;
- 154 hearing offices;
- 7 satellite offices;
- 5 National Hearing Centers; and
- 1 National Case Assistance Center.
We are well-positioned to assist LEP populations through our network of public-contact offices. We direct resources to LEP activities by:
- Hiring bilingual staff where bilingual skills are needed;
- Providing for contracted third-party interpreters at no charge to the individual;
- Providing for contract translations and typesetting services to produce non-English language materials; and
- Training our network of public-contact employees.
We identified 9,482 bilingual and multilingual employees, representing 138 different languages and dialects (Source: Office of Operations/Office of Public Service and Operations Support), who are serving the public in our Office of Operations’ components. From October 2009 to May 2010, 250 (9.44%) of the 2,649 total new hires in the Office of Operations were for positions requiring bilingual skills (Source: Office of Human Resources/Office of Civil Rights and Equal Opportunity). Out of the 250 bilingual hires, we placed 239 in permanent positions, including Contact Representative, Service Representative, Telephone Service Representative, Technical Support Technician and Social Insurance Specialist. The Office of Disability Adjudication and Review also increased its number of bilingual employees from 57 to 108 between FY 2007 and FY 2010, with bilingual position descriptions including Legal Assistant, Attorney Advisor, Attorney Examiner, Contact Representative, Translator, Language Specialist, Paralegal Specialist, Attorney Examiner, and Social Insurance Specialist.
When bilingual or multilingual employees are not available, we provide third-party interpreters at no cost to the requesting individual. Table 4 reflects annual expenditures for translation and interpreter services for our field offices and hearing offices (Source: Office of Operations/Office of Public Service and Operations Support and Office of Disability Adjudication and Review ).
|Table 4: SSA Expenditures for Translation & Interpreter Services|
Since October 2002, we have provided Telephone Interpreter Services (TIS). Our public-service employees can call TIS for connection with an interpreter to assist in interviews, phone inquiries, etc., for individuals with LEP. In FY 2010, we spent $3.9 million for TIS. In FY 2010, we provided foreign language interpreter services in 291,085 calls in 109 different languages and dialects. Table 5 reflects the most frequently requested languages (Source: Office of Operations/Office of Public Service and Operations Support ).
Table 5: FY 2010 Telephone Interpreter Services;Top Five Requested Languages
Number of Calls
|Chinese (Cantonese & Mandarin)||21,884|
As shown in Section 2 above, in February 1995, we chartered an LEP inter-component workgroup, which met on a regular basis and was responsible for our LEP activities. The Office of External Affairs (OEA) previously led our activities. As a result of Attorney General Eric Holder’s February 17, 2011 memorandum reemphasizing LEP services, we escalated oversight responsibility of LEP services to the Deputy Commissioner of Social Security.
We also reconvened the LEP inter-component workgroup and conducted a self-assessment of our current LEP services and updated this plan.
The LEP Workgroup will meet regularly over the next eighteen months to research and review our LEP services. The workgroup will report its findings and make recommendations for improvements to the Deputy Commissioner and our executive leadership team.
Our public-contact employees and public affairs specialists conduct outreach activities to individuals with LEP at the national, regional, and local level. OEA works to ensure that individuals with LEP are aware of and have access to our LEP services. Our most recent activities include:
- Conducting a LEP workshop at the Hmong National Conference in April 2011;
- Conducting a two-way information gathering event on Spanish online applications with bilingual advocates at the International Trade Commission Building in Washington DC on March 10, 2011;
- Promoting our service to individuals with LEP at the National Legal Aid and Defenders Association’s training conference in November 10 – 13, 2010;
- Participating in the federal roundtable discussion at the Asian American Justice Center’s annual conference on June 23 – 24, 2010;
- Discussing our LEP services at the Asian American & Pacific Islanders federal roundtable on June 3, 2010; and,
- Meeting with the National Language Access Advocates Network representatives in March 2010.
Our improvements in LEP services delivery include:
- Offering a Spanish language version of our online “Retirement Estimator.”
- Revising our “Complaint Form for Allegations of Discrimination in Programs or Activities Conducted by SSA” (SSA-437) to clarify that we accepted complaints alleging discrimination on the basis of a limited ability to speak English.
- Developing our “En Español” website http://www.socialsecurity.gov/espanol/, which contains publications and information in Spanish.
- Providing written materials in languages other than English through our Multilanguage Gateway at http://www.socialsecurity.gov/multilanguage/. (We updated and posted 46 publications on a variety of our programs to the Multilanguage Gateway in each of the following languages: Arabic, Armenian, Chinese, French, Greek, Haitian Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese.)
- Creating an “Interviewing Guide” and training materials for our employees, in Spanish, Vietnamese, Navaho, Polish, Chinese, Russian, Filipino languages, German, French, Haitian Creole, Italian, Korean, Arabic and Portuguese.
- Translating our “Interpreter Service Policy” poster in 19 different languages, which we display in our field offices.
As a result of our self-assessment activities and revision of our plan, we have renewed our commitment to language access obligations under Executive Order 13166. We found the Department of Justice’s “Language Access Assessment and Planning Tool for Federally Conducted and Federally Assisted Programs” very useful in identifying our current services and identifying areas where we can seek improvements.
We will continue to follow the factors and policy principles outlined in this plan as well as use technology and other available resources to identify opportunities to improve LEP services.