Accessibility. Reporting Interpretation and Accommodation Requests

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1 A presentation by: The WorkSmart Network Accessibility Reporting Interpretation and Accommodation Requests Version

2 Overview As subrecipients and contractors of Federally-funded programs and activities, we have a responsibility to provide meaningful access and equal opportunity to services.

3 The laws Federal civil rights laws prohibit discrimination of members, applicants, enrollees, and beneficiaries in programs and activities that receive Federal financial assistance. The laws include: Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990, Title IX of the Educational Amendments of 1972, the Age Discrimination Act of 1975, and Section 1557 of the Patient Protection and Affordable Care Act of 2010

4 Key populations Limited English Proficiency Individual: a customer who cannot speak, read, write, or understand the English language at a level that permits them to access program services and benefits in a meaningful way. Disabled Individual: a customer with a physical or mental impairment that substantially limits one or more of the major life activities; a record of such an impairment; or, being regarded as having such impairment.

5 The laws (continued) These laws prohibit recipients and subrecipients of Federal financial assistance from discriminating on the basis of race, color, national origin, sex, age, disability, and, in some programs, religious creed or political affiliation or beliefs, in their service delivery, and from engaging in retaliation against those who oppose discriminatory practices protected by Federal civil rights laws.

6 Our responsibility Provide services and programs in the most integrated setting appropriate to the needs of the qualified individual with a disability; Ensure that programs, services, activities, and facilities are accessible; Make reasonable modifications in their policies, practices, and procedures to avoid discrimination on the basis of disability, unless it would result in a fundamental alteration of the program;

7 Our responsibility (continued) Provide auxiliary aids to persons with disabilities, at no additional cost, where necessary to afford an equal opportunity to participate in or benefit from a program or activity; Designate a responsible employee to coordinate their efforts to comply with Section 504 and the ADA;

8 Our responsibility (continued) Adopt grievance procedures to handle complaints of disability discrimination in their programs and activities; and, Provide notice that indicates: That the covered entity does not discriminate on the basis of disability How to contact the employee who coordinates the covered entity s efforts to comply with the law Information about the grievance procedures

9 Our responsibility (continued) Provide language assistance services, including translated vital documents and oral interpretation, free of charge and in a timely manner, when such services are necessary to provide meaningful access to LEP individuals.

10 Interpretation accommodations Accommodation examples: Oral interpretation Bilingual or multilingual staff Professional interpreter services (Language Line) Volunteer interpreters Vital document translation

11 Blind, visually-impaired accommodations Accommodation examples: Braille Large print/magnification software Audio recordings Accessible electronic formats that can be read by screen reading software Optical readers

12 Deaf, hard of hearing accommodations Accommodation examples: Sign language, oral, and cued speech interpreters Video remote interpreting services Open and closed captioning of videos Real time captioning Photo courtesy: American Sign Language Teachers Association

13 Interpretation example Ken, a Career Planner, is meeting with Julie to discuss program eligibility. In the appointment, he recognizes Julie has challenges communicating in English. He learns that her primary language is Spanish. Ken offers to bring in an interpreter (via Language Line) to aid in the communication. She agrees and Ken arranges the service through Language Line to continue the appointment. What s Next? After the appointment ends, Ken should notify the One-Stop Operator of the use of the Language Line service. Next, he must report the instance in the Accessibility Reporting Google Sheet.

14 Reporting an accepted interpretation request 01 Record interpreter engagement in Accessibility Services Google Sheet, using the Interpreter Service tab 02 If interpreter service is offered and accepted, document the date, staff name, offered translation service accepted by LEP Individual (select Y), translation service provider, language group, translator phone, translator name and include any pertinent comments 03 Notify the One-Stop Operator if a contracted interpreter service (i.e., Language Line) was used for the engagement IMPORTANT: Document each instance in which an interpretation service offered.

15 Reporting a declined interpretation request 03 If interpreter service is offered and refused, collect a signed Acknowledgement/Refusal of Interpreter Services Form from the individual during the engagement 04 Submit the Acknowledgement/Refusal of Interpreter Services Form to the One-Stop Operator within 10 business days AND retain a copy of the form in the participant case file (see Case File section divider for guidance) if applicable IMPORTANT: Document each instance in which an interpretation service offered.

16 Interpretation options In instances where the LEP person insists on using an adult family member or friend as interpreter, subrecipients and contractors must ensure that the LEP individual understands that the agency would otherwise provide a qualified interpreter free of charge. Next steps In situations like this, recipients or subrecipients should go over LEP individual s interpretation rights and decision as to those rights using the Acknowledgement/Refusal of Interpreter Services Form. (Available in Google Drive.)

17 Accommodation example Alex signs up for a resume workshop. Before the workshop, he contacts Tara to explain he has difficulty reading small print. Tara asks Alex what accommodations he needs and makes arrangements. Alex will be seated at a table nearest the presentation screen and screen font is scaled at 18pt or higher to reduce visual stress. She also makes available a magnification tool for Alex at the workshop. What s Next? After the workshop, Tara should report the instance in the Accessibility Reporting Google Sheet, under the accommodations tab.

18 Reporting an accommodation request 01 Record accommodation service(s) in Accessibility Services Google Sheet, using the Accommodation Service tab IMPORTANT: Document each instance in which an interpretation service offered.

19 Resources For more help, check out these resources Civil Rights Plan (DWD) Language Line

20 A presentation by: The WorkSmart Network Questions? Version