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11 <br />The City does not currently collect data on which documents and programs are most accessed by <br />which LEP group. As such, it is difficult to assess the frequency with which LEP clients access <br />certain housing programs. Anecdotal evidence through conversations with City program staff <br />suggests that there has not been a great demand for translated documents. Even with the City’s <br />popular English/Spanish/Chinese documents, there has not been a need for an <br />interpreter/translated documents to date although there are two translation services and one <br />Chinese-speaking and several Spanish-speaking general contractors available to assist LEP <br />clients. <br /> <br />The LAP specifies a data collection program that will allow the City to more accurately assess <br />LAP program needs in the future. The data will be used to refine the LAP in the future to more <br />effectively serve LEP clients. As both a direct and indirect provider of services, the City will <br />assess which documents should receive written translation through a two-tiered assessment <br />framework: one tier for documents related to direct services; the second tier for indirect services <br />provided through CBOs. The framework is intended to be cognizant of the City’s and CBOs’ <br />limited resources while creating a LAP that provides meaningful access to housing programs and <br />social services for LEP clients. <br /> <br />Framework for Determining Vital Documents to be Translated <br />1. City staff will determine a list of vital documents related to programs and services that are <br />provided directly through the City. <br /> <br />A. Documents related to direct programs and services are automatically eligible for <br />written translation into Spanish and Chinese if they contain specific programmatic details <br />related to obtaining social services and/or benefits such as eligibility requirements, <br />application procedures, program terms, and applicant responsibilities. City staff will <br />determine if these documents should be translated in full, or if they should be in <br />translated in a condensed, summary form. <br />B. Vital documents may include, but are not limited to, program/service applications, <br />consent or complaint forms, notices of rights, public notices, documents containing <br />program information, program eligibility rules, notices advising of the availability of <br />language assistance, or outreach, and community education materials. <br /> <br />2. Documents related to City services provided indirectly through third party CBOs, and/or <br />documents that are not critical for obtaining social services and/or benefits will not automatically <br />receive written translation. Further assessment about the particular nature, need, and importance <br />of the document will be determined on a case-by-case basis. <br /> <br />A. Indirect program documents may include, but are not limited to: electronic <br />documents; web pages; newsletters; program/service reports; and press releases. <br />B. Documents that qualify as “vital” must first be assessed before potentially receiving <br />written translation. Assessment criteria include: <br /> <br />1. Whether the information is critical for a client/beneficiary to access social <br />services and/or benefits;