Language Access Plan

Access Plan Contents:

Related Documents:

Questions and Answers About Cleveland's Language Access Plan

What does LEP mean?

Limited English Proficiency (LEP) refers to an individual that has limited or no ability to speak, read, write or comprehend English at a level to effectively interact with native English speakers.

Why does Cleveland need to implement a Language Access Plan?

The City of Cleveland is committed to providing an inclusive and welcoming approach to interaction with all residents. As part of that commitment to inclusion the city is ensuring the accessibility of resources, services, and engagement regardless of language. Title VI of the Civil Rights Act of 1964 is a federal law requiring meaningful access to services for those with limited English proficiency. All federal, state and municipaldepartments and contracted vendors are required to adhere to such access.

How is “meaningful access” defined?

Ensure that all residents:

  • Have adequate information to understand the services and benefits available
  • Are able to easily access or receive services for which they are eligible
  • Are capable of communicating their circumstances or situations to City staff

What are Cleveland’s top spoken foreign languages?

Percentage of population estimation of language groups:

  1. Spanish (7.4%)
  2. Arabic (0.9%)
  3. Chinese [Mandarin, Cantonese] (0.7%)
  4. Russian [including Slavic and Serbo-Croatian rooted languages] (0.7%)
  5. Indic [Hindi, Urdu, Indo-European] (0.6%)
  6. French [combined with variety of African dialogues] (0.4%)
  7. Nepalese [newly arrived] (0.1%)

Source: U.S Census Bureau, 2010-2014 American Community Survey 5-Year Estimates

What does this plan cover?

This plan provides a description of the City of Cleveland’s 5 phases of the Language Access Program:

  • Phase 1: City-wide assessment of Language Access needs
  • Phase 2: Implementation of phone interpretation services
  • Phase 3: Implementation of written translation services
  • Phase 4: Employee Training and Ongoing Monitoring
  • Phase 5: Community Outreach

This plan also includes newly created City procedures and policies for effective language access and exhibits of instructional and informational materials that are essential to the Plan.

Responsibility for Ensuring Implementation and Ongoing Monitoring

A Language Access Working Group was formed with members from Cleveland City Council, the Office of the Mayor, and the Office of Information Technology and Services. The Group works collaboratively with all City departments to ensure implementation and ongoing monitoring. In addition to ensuring all necessary actions are taken to implement the Plan, the Working Group meets with department representatives regularly to determine additional language access needs.

Responsibilities of the Working Group include but are not limited to: Processing vital documents (see below) for translation and distributing documents to appropriate departments; Communicating essential information about the Plan to chiefs, directors, and commissioners; Designing and implementing employee training initiatives in collaboration with the Department of Human Resources; Providing technical assistance to employees using phone interpretation service; Providing all necessary instructional and signage materials for newly offered language access services; And monitoring departmental needs on aquarterly basis.


The City of Minneapolis’ guide “Minneapolis in Any Language” and the City of Chicago’s “Bridge the Language Gap,” among other resources such as were taken into consideration for the development of the following procedures and policies. Additionally, Legal Aid Society of Cleveland reviewed and offered suggestions to improve this Plan in collaboration with the Language Access Working Group.

City of Cleveland Language Access Plan Phases 1-5

Phase 1: City-wide Assessment of Language Access Needs; Date of Assessment Spring 2016

  • Implementation of Assessment:
    • Survey sent to each director/commissioner to obtain information on each department’s language access needs.
    • Language Access Working Group contacted each department as necessary to obtain additional information on needs.
    • Survey/meeting results compiled and analyzed to determine list of vital documents that needed translation and to determine need for interpretation services.
  • Assessment results:
    • 74 vital City documents were compiled for translation to Spanish.
    • Analysis determined need for phone interpretation services available to alldepartments, particularly public-facing departments whose employees regularly interact with City residents.

Phase 2: Implementation of Phone Interpretation Services; Date of implementation July 2016

  • Implementation:
    • Purchase order was initiated with vendor in July 2016 for phone interpretation services for every department.
    • The service has been live in the IT Call Center since July 2016.
    • The service will effectively go live for all departments when Phase 4 employee training is completed in 2017

Phase 3: Implementation of Written Translation Services; Date of Implementation September-November 2016

  • Implementation:
    • Purchase order was initiated with vendor in September 2016.
    • 74 vital City documents were received from the vendor as translated Spanish copies in November 2016.
    • Documents will be distributed to appropriate departments in 2017 during Phase 4 employee training.
    • Working Group will assess the need for additional document translation on a departmental basis.
    • Working Group will establish the use of “Babel” notices, notices placed at the bottom of vital documents to assist residents who need translated versions.

Phase 4: Employee Training and Ongoing Monitoring; Date of Implementation: January 2017-Present

  • Implementation:
    • In collaboration with TV20, a brief training video will be sent out to all employees. The video instructs employees on how to effectively use the phone interpretation service.
    • Language Access Working Group will work with all departments on assessing and meeting all training needs and gaps.
    • Working Group will work collaboratively with the Department of Human Resources to roll out effective training initiatives for new and current employees to use phone interpretation services.
    • Language Access Working Group will meet with department representatives on a quarterly basis to review phone interpretation usage and support any additional language access needs.
    • Language Access Working Group will have ongoing discussions around creating a complaint process for residents who have concerns about the provision of language access services.

Phase 5: Community Outreach; Date of Implementation April 2017

  • In collaboration with TV20, Working Group will roll out series of commercials advertising new services in various languages.
  • Working Group with work with Community Relations Department on outreach visits and informational materials to community groups that work with LEP residents.
  • Working Group will work with area organizations like Global Cleveland to conduct outreach to LEP residents.

Implementation Timeline

Task Completion Dates

  • Phase 1 Spring 2016
  • Phase 2 July 2016
  • Phase 3 November 2016
  • Phase 4 January 2017
  • Phase 5 May 2017

 City of Cleveland Language Access Plan Procedures & Policies

Notice of Availability of Services

Signage materials indicating the availability of interpretation services include Language ID Laminated Guides, Language ID Posters, and Language ID Desktop Displays for departmental reception areas. Materials will be distributed to departments as needed and will indicate to LEP residents the availability of interpretation services in their native language.

Written Translation Policy

Translation is the conversion of written communication from one language to another. An accurate translation is not necessarily word for word, rather conveys the whole meaning of the original text. City of Cleveland must provide professional translation of vital documents free of charge and in a timely manner to people who speak little or no English if requested or if necessary to ensure effective accessibility to City resources, services, and engagement.

Vital Documents Policy

Information or documents that are critical for accessing federally funded services or benefits, or are documents required by law to include but are not limited to the following:

  • intake, consent, complaint or otherwise essential forms;
  • applications to participant in, or receive benefit from services or programs; and
  • standard forms such as permit applications, birth and death certificates
  • written notices of eligibility criteria, rights, denial, loss or decreases in benefits or services

NOTE: While many vital documents will be immediately available in other languages on the City's website, not all vital documents will be translated. Upon request, any vital document must be translated in a timely manner in the requested language.

Non-vital documents that do not qualify for free translation:

  • handbooks;
  • third party documents, pamphlets or forms;
  • general information that can be found on the website (which is translatable)

Procedure to get additional documents translated

The City of Cleveland has a contract with a professional interpreting company and documents should only be translated through their services or by a professional translator. Employees should not use free online translation services without a professional translator reviewing the content. Residents can request document translation services from employees or employees can utilize translation services when appropriate to allow for effective access to services. Submission process instructions will be provided to departments with instructional packets.

Policies for interpreting

  1. Interpreters must be offered at no cost, to individuals who speak little or no English if such individual requests interpretation services or if the city staff member determines communication is not possible without interpretation services. Interpretation services must be provided in a timely manner.
  2. Interpretation can be provided for public meetings and events if requested with at least a five-business day notice. Public meeting notices shall include a line advising LEP residents that interpreters will be provided upon request if there is at least 5 business days notice.
  3. All interpreters must:

a. be linguistically competent (have the ability to demonstrate fluency);
b. have prior professional experience;
c. practice with cultural humility regarding the English language learners situation and culture; and
d. abide by the City of Cleveland’s code of ethics and professional standards

    4. Volunteers, family members or friends should not be allowed to interpret unless they are competent (demonstrate fluency)

     5. Children MAY NOT interpret

Information and Technology Services Policy

The City of Cleveland’s Office of Information and Technology Services will add a translation widget powered by Google Translate to all websites maintained by the City. This will allow online users to access information remotely with the same commitment to equal access.

Any translated content that a department has available for public download should also be submitted to the IT department for upload to the site. If an application is available for download from a City website, the respective translated application should be available for download as well.