SUBJECT:

LEP persons must not be:

• required to find their own interpreter; AND
• denied basic information about benefits and services for which they are eligible; AND
• turned away from applying or requesting services; AND
• forced to wait for long periods of time before effective communication can occur; AND
• required to make repeated visits to offices until an interpreter is available.

Use one or more of the following to comply:

1. Contracted Trained and Competent Interpreters:

Use a vendor that has a statewide contract from the Missouri Office of Administration.  Each office can verify the list of contracted firms by accessing www.oa.state.mo.us/purch/contracts/service.htm on the internet or by contacting our Management Services unit to request a written copy.   If using a statewide vendor is not feasible, purchase the interpreter services locally; however, a Purchase Request, DBF-1 form, must be approved if the annual costs will exceed $3,000.

2. Community Volunteers:

Utilize community organization volunteers who are competent and understand their obligation to maintain client confidentiality.  Make formal arrangements to obtain such services if available.
 
3. Bilingual Staff:

Using bilingual employees who are trained and competent in interpreting is permissible.

4. Telephone Language Services:

Use Language Line ® to supplement the above methods.  IM Memorandum #164 of 1999 announced our agreement to get telephone interpretation. 

We recently sent each county office a Translation Service Available poster and Language Identification Card.  To help identify the foreign language spoken, keep the poster in a prominent place in the reception area of the office near the receptionist.  Use the Language Identification Card to identify other languages spoken.

Restrictions on Using Friends, Family and Minor Children as Interpreters:

The Office of Civil Rights has ruled that the use of friends, family and minor children as interpreters could cause a breach of confidentiality or reluctance on the part of the LEP person to reveal important information.  If the LEP person refuses staff's offer for a free interpreter, document this in the case record, suggest that a trained interpreter be present to ensure accuracy, and then, use the family member or friend. 

Recording Identified Languages:

Once a person's foreign language has been identified, record it in the case record so persons looking at the record can easily identify the language of the LEP person.

Local Office Responsibility:

Each office must:

1. ensure that staff is aware of and follows these requirements; AND
2. establish procedures staff can follow locally to access interpretative services as soon as possible; AND
3. make necessary arrangements with community organizations and local interpreters as needed; AND
4. identify the foreign languages that employees are likely to encounter. 

• Discuss this memorandum with all appropriate staff.

• Offer free language interpreter services to LEP persons.

• Develop local plans to provide interpreter services.

• File the manual revision pages in Chapter XII.

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