The US Department of Health and Human Services Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons describes various options available for providing oral language assistance including the use of bilingual staff, staff interpreters, or contract interpreters…The guidance stresses that interpreters need to be trained and competent, though not necessarily formally certified, and discourages the use of friends and family members, particularly minors, as interpreters…

Four-Factor Analysis

The extent of responsibility can be determined using an individualized assessment that balances the following four factors:

Number or proportion of LEP persons eligible to be served or likely to be encountered by the program or grantee Frequency with which LEP individuals come in contact with the program Nature and importance of the program, activity, or service provided by the program to people’s lives; and Resources available to the grantee/recipient and costs. Safe Harbor:

Actions considered strong evidence of compliance with written-translation obligations:

Written translations of vital documents for each eligible LEP language group that constitutes 5% or 1000, whichever is less, of population served. If 5% includes less than 50 persons, providing oral interpretation of written materials and notice of such right.