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14 <br />communications, and heightened collaborative efforts among our network of agencies and encourage <br />small-scale focus groups/discussions with clients. <br /> <br />The City anticipates that some organizations may face significant resource constraints, a factor which <br />should be documented. The intent of federal LAP guidelines is to ensure meaningful access to <br />programs for LEP persons, while simultaneously doing so within an organization's resource capacity. <br />The City will work with these organizations on a case-by-case basis to determine reasonable levels of <br />service based upon the organizations' capacity and resources. The organizations should assess the <br />type of document requiring translation and the appropriate level of service (e.g., oral translation <br />versus summary translation). Each organization should develop its own LAP when feasible which <br />should be incorporated with the federal grant application and review process through the City’s <br />Community Assistance Grant Program. <br /> <br />It should be noted that smaller subrecipients with more limited budgets are not expected to <br />provide the same level of language services as the larger subrecipients with larger budgets. <br />“Reasonable steps” to provide services to LEP clients may also cease to be reasonable when the <br />costs imposed substantially exceed the benefits. Resource and cost issues can be mitigated by <br />sharing language assistance materials and services among and between recipients, advocacy <br />groups, and federal grant agencies. Grant recipients need to explore carefully the most cost- <br />effective means of delivering competent and accurate language services before limiting services <br />due to resource concerns. <br /> <br />The City has long-standing partnerships with subrecipients, and they have the programs and <br />services that LEP clients are likely to access. Many of these organizations already have bilingual <br />staff and translated documents, such as fair housing and other resource documents, for LEP <br />beneficiaries. City staff will collaborate with these organizations to help them develop their <br />plans. However, implementation of any expanded LEP-related services will be challenging now <br />and possibly delayed due to the severe revenue cuts all of these agencies are experiencing. <br /> <br />Monitoring and Plan Updating <br />The City’s LAP includes provisions to collect data so that demand for housing programs and <br />services by LEP persons can be more accurately assessed. The data will be used to refine the <br />LAP in response to the measured need. <br /> <br />To provide effective LAP services for LEP clients, implementing agencies must monitor their <br />plans and adjust them, as necessary, according to client needs. The City will review our LAP <br />periodically to determine current effectiveness and to analyze any changes in LEP populations or <br />needs. Collecting, analyzing, and maintaining data is one way that the City may assess the <br />efficacy of our LAP. Without data, it is difficult to assess the true need and demand for LAP <br />services. The LAP should explore procedures for collecting and maintaining data on each <br />encounter with a LEP client. The data may include the following: <br /> <br />1. Method of communication (telephone or in-person); <br />2. Type of language need (Spanish, Mandarin, Cantonese, etc); <br />3. Type of language service needed (oral or written translation); and, <br />4. The program being accessed (housing rehabilitation, fair housing, childcare programs, etc.). <br />