The Application Process For TANF, Food Stamps, Medicaid, and SCHIP

Chapter 6.
The Language Dimension of Applying for Assistance:
Strategies to Meet the Needs of Limited English Speakers

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Contents

This chapter addresses the issues faced by Limited English Proficient (LEP) individuals when applying for public benefit programs and the ways that localities have attempted to address these issues. It describes the major strategies used by the study sites to provide language services to LEP applicants, discusses some of the trade-offs associated with different strategies, and summarizes the primary approaches used in each site.

Key Language Access Strategies

Localities employ a variety of strategies to facilitate communication with LEP public assistance applicants. Some strategies place a greater share of responsibility on agencies to provide language services for limited English speakers while others rely more on applicants to assume this responsibility. Because no single strategy is able to meet the needs of each LEP applicant, most sites employ multiple language access strategies.

Bilingual Staff

Public agencies often rely on interpreters who speak the native languages of LEP applicants to help these applicants negotiate the application process. Interpretation services may be provided by in-house agency staff either as part of or in addition to their regular job duties. These services may also be provided by private contractors who are hired solely for the purpose of providing interpretation services. Each of the study sites, except Sedalia, fills some eligibility staff positions with bilingual workers. Seattle is the only site that has bilingual agency staff but also relies primarily on contracted interpreters for language assistance when conducting eligibility determination interviews.

Using bilingual eligibility staff to address language barriers has the added advantage of safeguarding program integrity as eligibility determination can require lengthy and involved applicant-worker interaction, often covering complex information, that affects both eligibility and benefit levels. However, as highlighted in Chapter 3, the application process often involves activities and interactions with staff other than eligibility workers. Therefore, language assistance is often needed at each stage of the application process (e.g., initial intake and screening, in addition to eligibility interviews). While some localities place bilingual staff in reception or screening roles (New York, Dallas, Arlington, and Raleigh), the extent to which bilingual staff are available to cover these functions varies considerably across the sites.

Discussions with program staff, advocates, and applicants indicated that bilingual staff are needed not just at the eligibility interview but also during the initial steps of the application process (e.g., initial reception/intake, screenings, orientations). Otherwise, some expressed concern that some limited English speakers can be deterred from applying before completing the application process. However, agencies can find it difficult to match limited English speakers with bilingual staff at each point of contact during the application process, especially in places where there is substantial language diversity or a complicated application process that involves several steps and interactions with different types of staff.

Given that it is generally infeasible to match bilingual staff with limited English speaking applicants at every conceivable point in the application process, a common strategy is to make bilingual staff readily available to interpret on an as-needed basis. While this may be an effective fallback strategy, it appears to have downsides when used as a primary approach. Most importantly, it diverts workers from performing their own job responsibilities, which may negatively affect staff productivity and efficiency. For example, some bilingual eligibility staff noted that they are routinely pulled away from their own casework — even during interviews with other applicants — to interpret in the reception area or for another eligibility interview. Agency administrators and managers also discussed the difficult management challenges presented when attempting to balance the workloads of monolingual staff against bilingual staff that provide interpretation assistance on an as-needed basis in addition to their regular job duties.

In several sites (Arlington, Dallas, and New York), some bilingual workers voiced reluctance to identify their language skills because they do not want to be asked to perform extra work without additional compensation. Among the study sites, Seattle is the only site with a system for certifying and financially compensating bilingual staff — a strategy employed on a statewide basis.(1) When bilingual staff are not compensated for providing interpretation services in addition to their other job duties, the practice of using bilingual staff to interpret on an on-call basis also may be opposed or viewed negatively by unions. In New York City, for example, some staff commented that the union representing eligibility workers advises bilingual staff not to make their language skills known.

As a primary language assistance strategy, relying upon in-house bilingual staff is less practical and effective in localities experiencing a significant degree of language diversity. New needs for language assistance typically appear with each new wave or expansion of immigrant groups. Therefore, to accommodate the continually changing language composition of the applicant and client pool, staffing strategies need to be flexible. However, bilingual individuals interested in and capable of working for welfare agencies may not be readily available. In addition, agencies cannot terminate bilingual staff who speak certain languages simply because there is no longer as much demand for those languages. Because many public agencies’ workforces are unionized, the ability of agencies to adjust the composition of their permanent agency staff to meet each new language need may be further constrained by rules regarding hiring, delineation of job responsibilities, and other union concerns.

A promising alternative strategy is to use private interpreters on a contract basis to provide language services for some functions. Washington State is the only state represented in this study, which uses this approach, although implementation varies somewhat across local offices.(2) For example, the Seattle/Rainier office uses private, contracted interpreters at both the initial reception/intake stage and the eligibility interview stage whereas the Seattle/Kent office reserves their use for eligibility interviews. Based on our discussions, it appears that staff and program administrators in Seattle are generally quite pleased with this approach. The primary drawback is that these private interpreters are not trained in agency rules and procedures and staff cannot be certain that the information is fully and correctly translated. However, staff generally stated that the contracted interpreters do a good job and that it is an effective strategy for meeting the challenge of addressing diverse and changing language needs.

This approach may not work as well in sites lacking sufficient interpreters in the community who can be hired on a contract basis. In addition, sites with relatively low demand for interpretation in various languages may find it difficult to justify expenditures for part-time or full-time contract interpreters. It might also seem inefficient to use private interpreters instead of in-house bilingual staff for eligibility interviews because two individuals instead of one are required to carry out a single function. But, in both Seattle offices visited for this study, workers generally said that using private contractors does not seriously increase the length of the eligibility interview. Workers said they make up for the extra back-and-forth of the interpretation by entering information into the case file as their questions are being translated.

Reliance on Community-Based Organization (CBO) Staff

In all of our sites except Seattle, public agencies rely on local CBOs to provide interpretation services, generally free of charge. Specifically, agencies often turn to resettlement agencies to provide interpretation for refugee applicants. In most of the study sites, agency staff reported that refugee resettlement agencies often help refugees with limited English proficiency complete benefit applications before they come to the office.

Aside from refugee agencies, local CBOs, often with immigrant or ethnic affiliations, also assist with interpretation and application assistance. Because CBO staff have other responsibilities and are not always immediately available when the applicant arrives at the welfare office, some agency workers reported increased waiting times for limited English speaking applicants when CBO staff are asked to serve as interpreters.

Language Phone Banks

Because of constraints on hiring bilingual staff to match the language needs of all applicants, staff often turn to language phone banks to provide interpretation. These language lines may be agency-run but are more commonly privately operated. Of the study sites, only New York City has developed an in-house call center, staffed by experienced eligibility workers, to provide interpretation in the city’s top four languages. Private language lines are used on a limited basis in Dallas and New York City. Although this service is also available in Arlington, Sedalia, and Seattle, workers there reported that they virtually never access it.

The primary benefit of private language lines is their extensive language coverage, which includes interpretation in over 140 languages. But, according to program administrators, private language line calls are expensive. In New York City, there is a call log to record each use of this service, which reportedly discourages use by some workers while others simply opt not to use it because it is too cumbersome and time-consuming. Some workers reported that using the HRA language line instead of an in-house bilingual worker increased the eligibility interview duration on average by 40 minutes.

Another disadvantage with private language lines, as with private interpreters, is that these phone interpreters are not trained in the agency’s programs and jargon. For both the private and agency-run lines, agency staff also noted that using these lines can be problematic on a more basic level because they may not have access to speakerphones that facilitate easy three-way communication. Workers reported frustration and confusion with having to pass the phone receiver between themselves and their clients. According to some advocates and eligibility workers, phone interpretation services also reduce interpersonal contact between workers and applicants, thereby increasing opportunities for misunderstandings.

Reliance on LEP Applicant Family/Friend Networks

Another common means of providing language services is to rely on friends and family of the limited English-speaking applicant to interpret for them. In each of our sites, except Seattle, the use of family and friends as interpreters is a common practice — especially for speakers of less common languages. Limited English speaking applicants often rely on family members or friends who are more English proficient, but may still have trouble interpreting the technically rich vocabulary of public agencies. Eligibility workers routinely commented that use of family members and friends as interpreters calls into question the accuracy of the information provided. Workers also noted that using family and friends as interpreters often increases the length of the interview because of the extra time required to communicate complex eligibility questions. However, when agencies are not equipped to provide interpretation services for non-English speakers, particularly for those speaking less frequently encountered languages, public agencies leave applicants little recourse but to turn to friends and family for interpretation assistance.

Use of Written Aides/Translation of Written Materials

Human service agencies often use translated materials, notices, and applications to help facilitate communication with limited English proficient applicants. For example, "I speak" cards posted at the reception desk or language posters in reception areas help applicants identify which language they speak. Most of the sites have "I speak" cards or language posters; however, they are not always clearly displayed and usually only cover a subset of languages spoken by applicants. While these cards and posters do not help those who are illiterate in their native language, most workers reported that applicants are usually able to state the name of their native country or language. Overall, workers tend to view initial identification of the language spoken by the applicant, regardless of the presence or absence of "I speak" cards or language posters, to be the least problematic aspect of communicating with these applicants.

Public agencies — particularly welfare offices — extensively rely on written materials and notices for the vast majority of client-agency communication. Requests for documentation and changes in program requirements are often conveyed exclusively by mail. During the application process, providing written translation of even simple things like lists of required documents can increase the likelihood that applicants will comply with application rules and be determined eligible.

The availability of translated written documents is often a missing or undeveloped element of localities’ language access strategies. As documented in more detail in Chapter 4, even the basic integrated application forms are available only in English in half of the sites (Arlington, Raleigh, and Sedalia) and only a Spanish translation is available in Dallas. Separate Medicaid/SCHIP application forms had been translated into Spanish in all sites, although they were not available through New York City’s Medicaid/SCHIP facilitated enrollers at the time of our site visits.

To bridge this gap in written translations, staff may take it upon themselves to translate forms or find a staff person who can do so for them, but this appears to be largely an informal, ad-hoc practice. In Arlington, where forms are only available in English, one worker said little could be done beyond impressing upon LEP applicants the importance of keeping every letter with a government seal on it and finding a family member or friend who can translate it for them. Beyond the need for translated versions of written documents, staff and applicants also noted that illiteracy in the LEP applicants’ primary language is also a common problem.

Washington State has made the most progress in providing written translation of agency materials. The state welfare agency translates and provides all notices, integrated applications, and major agency communications in the seven state-supported languages (Chinese, Cambodian/Khmer, Laotian, Korean, Russian, Spanish, and Vietnamese). To serve those speaking less common languages, the state welfare agency contracts with private companies to translate written notices and major written communications into another 86 languages on an "as needed" basis. The extensive translation of materials does not extend to Medicaid/SCHIP applications, which are only available in English and Spanish.

It is estimated that about 3,500 to 4,000 agency documents are translated into 60 or 70 different "unsupported" (or non state-supported) languages each month. If the agency is unable to translate a written notice or major written communication into an unsupported language within three days, a notice to that effect is supposed to be sent to the applicant (or ongoing client) in English with a statement written in the client’s primary language informing the client to take the notice to a local office for oral translation.

New York City announced in Spring 2002 that FSP notices are now available in eight new languages (Arabic, Chinese, French, Haitian Creole, Korean, Russian, Vietnamese, and Yiddish). Translations in English and Spanish were already available. As a part of this effort, over 60 food stamp forms and notices were translated.

Even with these comprehensive systems, there can be glitches. For example, some local agencies reported that the average turnaround time for written translations ranges between seven and ten days, although the wait may be longer or shorter depending on the language requested. This delay may place applicants at risk of not meeting the post-eligibility interview ten-day application processing timeframe. In addition, advocates and outreach workers emphasized that the quality of the translated forms is not always satisfactory. Translations of technical terms can be extremely hard to understand and the reading level required to understand the translated material can be prohibitively high. Some workers pointed out that English speakers also often find the written materials (including application forms) difficult to read and comprehend, suggesting that poor quality translations are a reflection of a more systemic problem.

Increasing the Quality of Interpretation and Translation Services
The Washington State Example

In response to a settlement between the Department of Social and Health Services in Washington State and language-access advocates in 1991, the state developed a system to test and certify the language ability of interpreters and translators working for this agency. Under this system, the state agreed not only to provide and pay for interpreters and translators, but also to certify their language skills to ensure that high-quality services are provided to LEP clients. This level of quality control is unique in the study sites.

Workers are tested and certified in English and eight foreign languages (Chinese, Cambodian/Khmer, Laotian, Korean, Russian, Spanish, and Vietnamese). These tests are administered to different levels of workers, including: agency employees with bilingual assignments, licensed personnel providing services under contract, contracted translators providing written translation for the agency, and contracted interpreters providing oral interpretation in medical settings to the agency’s clients. In response to concerns about the quality of language services provided in languages other than the state’s eight most common languages, an English language test is now being administered to all interpreters and translators.

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Multiple Language Access Strategies:  Local Level Examples

Based on this study of six sites, it seems clear that there is no single language-access strategy that is appropriate for every program or each stage in the application process, let alone for all language groups. As a result, localities in our study tend to employ several language access strategies simultaneously. The design and implementation of these multiple local language access strategies are driven by a complex interplay of factors related to:

Developing strategies that take into account these factors is challenging because the size, composition, and distribution of immigrant populations are often moving targets.

Since a single language access strategy cannot fulfill all language needs, one way to conceptualize language access approaches at the local level is in terms of how quickly the agency responsible for determining eligibility must turn to LEP applicants to devise their own interpreters. Among our sites, some agencies place more responsibility for successful communication on LEP applicants, while others shoulder more of the burden themselves. In practice, this typically translates into the agency assuming responsibility for the first or primary language access strategy but second or third alternatives may rely on LEP applicants themselves and/or on family members or community-based organizations.

A Multi-Tiered Approach: New York City

New York City is the nation’s major immigrant receiving city. The sheer size and diversity of its immigrant population places intense and unique demands on agencies responsible for delivering public benefits. At the time of our visits (June and December 2001), New York City was implementing a new policy for handling LEP applicants in the city’s TANF and food stamp offices that emphasized a multi-tiered approach. The approach was developed by the Office of Refugee and Immigrant Affairs (ORIA), a new office within the Human Resources Administration (HRA) established in Spring 2000 to improve access to public benefit programs for limited English proficient individuals.

New York City has implemented a multi-tiered approach to handling limited English speakers in all Job Centers:(3)

This approach has not been integrated into the Eligibility Verification Review (EVR) process, a mandatory step for all cash assistance applicants that includes an additional interview, verification of documentation and home visits.

Another key component of New York City’s language access strategy is the creation of specialized Refugee and Immigrant Job Centers designed to primarily serve LEP applicants and clients whose primary language is neither English nor Spanish.(4) Routing clients who meet these criteria to centralized locations makes it possible to physically concentrate staff with bilingual capacity for less common languages. In sites where large numbers of limited English proficient individuals speak one or more languages and there is sufficient staff capacity, this centralized approach presents a promising model for providing effective language services (see box below).

Meeting Language Needs Through Specialized Offices:
The New York City Example

To accommodate the tremendous diversity of language needs in New York City, the Human Resources Administration has established two specialized Job Centers with a consolidated force of bilingual workers. Like their non-specialized counterparts, these specialized Job Centers process TANF/FSP/Medicaid applications and provide ongoing case maintenance and services. The first specialized Refugee and Immigrant Job Center opened in April 2001 in lower Manhattan. A second specialized office of this kind opened in January 2002 in Brooklyn. The Brooklyn Refugee and Immigrant Job Center expanded the overall number of language groups served by including languages not covered at its Manhattan counterpart and does not serve Spanish speakers. Approximately 90 percent of cases handled by these offices are limited English proficient. Together, the centers serve about 6,000-6,500 cases, a small but significant share of the city’s limited English speaking public assistance caseload — estimated in June 2001 to be about one-fifth (19 percent or 31,833 cases) of the public assistance caseload.

This model is viewed as a far more efficient and comprehensive alternative to addressing the diverse language needs of applicants and clients by thinly spreading bilingual staff across the city. Its implementation required drawing existing bilingual staff from other offices across the five boroughs. Program administrators believe this is a better deployment of staff resources to meet the language needs of its clients even though it reduces the number of bilingual staff and the language capacity in regular assistance offices. Importantly, the City’s public transportation system is extensive, making it possible for refugees and immigrants from different parts of the City to travel to a centralized location. At the same time, the centralization of bilingual staff in specialized offices increases the travel time involved for these LEP applicants and clients.

Smaller localities might have insufficient demand to support even one specialized, multilingual office. However, they could still adopt a modified version of this approach by establishing specialized LEP eligibility units within existing offices.

How the multi-tiered strategy employed across all Job Centers combined with specialized Job Centers plays out in practice differs across the offices we visited and largely depends on the language capacity of the in-house staff at each center. At one of the 30 non-specialized Job Centers in New York City, reception staff immediately turn to CBOs to provide language assistance if the LEP applicant does not speak English or Spanish. At the specialized Refugee and Immigrant Job Centers, however, more languages are covered in-house and so there is generally less need to rely upon outside interpreters. There are occasions, however, when in-house bilingual staff are not available. One of the specialized centers is located in the same building as a refugee resettlement agency and eligibility workers will call upon their staff for interpretation assistance. Significantly, staff at this Job Center noted that they never need to resort to the private language lines for interpretation assistance.

Developments occurring in New York City’s evolving language access strategy since the site visits took place include moving toward contracting for some interpretation services to fill the existing gap in capacity to deal with less common languages. Four contracts totaling $100,000 for on-call, on-site interpreter services were targeted for use by Medicaid/SCHIP offices (to assist in efforts to transition eligible Disaster Relief Medicaid recipients to the regular Medicaid/SCHIP program), the two specialized Refugee and Immigration Centers, and programs providing domestic violence and adult protective services. As of April 2002, Medicaid/SCHIP administrators were revising their LEP policy to include access to the private phone line and the new on-site, contracted interpretation services.

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Responding to Increasing Language Diversity

In addition to New York City, three of our other sites — Arlington, Dallas, and Seattle — have institutional experience with serving significant numbers of LEP applicants. Yet, the LEP population in each of these localities has undergone significant changes over the last two decades as a result of shifts in the common countries of origin for newly arriving refugees. As a result, LEP applicants now speak many more languages, presenting agencies with the challenge of adapting their systems to keep up with new demand for interpretation of less common languages. For some of these more recent refugee waves, neither the human service agencies nor the larger community have sufficient language capacity to meet the increased demand. When this mismatch in language capacity and needs occurs, there is an increased tendency by agencies to rely on friends and family members of LEP applicants for language assistance.

Arlington, Virginia

In Arlington, the strategies used to provide language assistance depend greatly on the language spoken by the LEP applicant. The first preference is to provide language services through a bilingual staff member. Bilingual staff are predominately Spanish speaking, although there are some additional languages spoken by bilingual staff in reception and case aide positions. Spanish speaking individuals, the predominant language group of LEP applicants, typically do not bring anyone with them to the office to interpret. The agency is able to accommodate their language needs with Spanish speaking eligibility workers or bilingual case aides who are used to interpret.

However, there are very few bilingual staff that speak languages other than Spanish. As a result, the primary strategy for non-Spanish-speaking LEP individuals is, by default, reliance on the applicant to bring a friend or family member. In addition, a refugee resettlement agency person is sometimes brought in by the applicant to interpret. Although it is office policy that such informal interpreters should only be used when the eligibility worker is satisfied that the interpreter is English proficient and adequately understands assistance programs, workers reported that they typically use whoever the applicant brings with them. Virtually all workers included in our visits are aware of the availability of the private language line for language services, but concerns about the cost of these services generally discourage the use of this option to the point that it is virtually never utilized. Thus, Arlington’s language access approach is essentially a two-pronged strategy: (1) in-house bilingual staff for Spanish speakers and (2) friends, family and, to a lesser extent, refugee resettlement organizations for speakers of less common languages.

Dallas, Texas

Spanish speakers dominate Dallas’ LEP caseload. In addition, Vietnamese-speaking applicants comprise a significant share of the balance of the LEP applicants in the city. At the time of our site visit in Summer 2001, the welfare agency employed few bilingual staff — for all language groups served — and these staff were concentrated in a specialized unit in downtown Dallas that only served refugees.(5) However, refugee applicants were not matched with bilingual eligibility workers who could communicate in their primary language, thereby mitigating some of the advantages of concentrating bilingual staff in a single location.

Within the non-refugee welfare offices, the lack of bilingual staff results in heavy reliance on applicants to provide their own interpreters. Although they have access to a private language line, some staff in local offices reported that they are reluctant to use the service because of a lack of speakerphones in the office (without which they must hand the receiver back and forth to the applicant). To bolster the supply of language interpretation services, the downtown Dallas office uses high school students to provide language services during the school year, but they are unavailable during the summer. Generally, CBO staff from refugee resettlement agencies are relied upon only to provide language assistance for the refugees they help to resettle — the same group that is also most likely to be served by bilingual agency staff through the specialized refugee unit.

Although not provided by the welfare agency, language assistance is available for Spanish-speaking LEP applicants who access Medicaid-only benefits at the main public hospital in Dallas. The hospital employs Spanish-speaking bilingual financial counselors, who screen patients for Medicaid eligibility. The hospital also employs Spanish-speaking interpreters who provide interpretation during Medicaid eligibility interviews conducted on-site by out-stationed eligibility workers employed by the welfare agency.

Seattle, Washington

The State of Washington began addressing language barriers in public benefit programs long before any of the other study sites, primarily because of a lawsuit filed in the late 1980s. Since the state signed a detailed consent decree with language access advocates in 1991, language access strategies have continued to evolve. Over the last decade, welfare offices in Seattle have fine-tuned different aspects of its language-access approach, including developing methods to deal with often overlooked language needs occurring during the application process, such as providing timely translation of written materials. Seattle has also begun to address the problem of ever-changing language populations by providing interpretation assistance — at the reception and eligibility levels — through contracted services, rather than by in-house, bilingual staff. The state also certifies bilingual workers in order to ensure that quality interpretation and translation services are provided for agency programs.

At the reception level, the Seattle/Kent office relies on the bilingual capacity of reception staff (which is minimal) or other staff in the office who are asked to interpret on an ad-hoc basis. If this fails, reception staff use interpreters brought by applicants or the private language line as a last resort. The approach at the Seattle/Rainier office is more comprehensive due to the availability of on-site contract translators. (See box, "On-the-Spot Interpretation: Seattle’s Block-Time Interpreters".) Reception staff in the Seattle/Rainier office turn to in-house bilingual staff for interpreter assistance only if on-site contractors are unavailable. As in the Seattle/Kent office, language lines are used only as last resort.

On-the-Spot Interpretation:  Seattle’s Block-Time Interpreters

Of our sites, the Seattle/Rainier office has the most comprehensive strategy for providing language services at the reception/intake level. Ensuring language assistance is available at the front-end of the application process complements a larger effort to more provide more up-front services at the reception level.

Although the receptionists at this office are not bilingual, interpretation is provided virtually seamlessly through the use of on-site, on-call contract interpreters called "block-time interpreters." LEP applicants communicate their language to the reception worker who then uses an intercom to immediately reach an interpreter stationed in the reception area.

The block-time interpreters cover ten languages: Arabic, Amharic, Cambodian/Khmer, Chinese (Cantonese and Mandarin), Lao/Thai, Oromo, Somali, Spanish, Tegrinnen, and Vietnamese and are available four days a week from 8 a.m. to noon. At the time of our visit, Somali interpreters were available full-time twice a week to meet the high demand for their services, but the office was preparing to scale back this availability because the demand no longer justified these expanded hours.

The Seattle approach is to provide interpretation during the eligibility interview to all limited English speakers through the use of private contractors, unless the applicant happens to be randomly assigned to an eligibility worker speaking their language. Although the Seattle offices we visited have significant numbers of bilingual eligibility staff, LEP applicants are assigned to workers by their last name (not language need) in order to address larger caseload management issues (e.g., making sure that cases are distributed equally across workers)

Providing such extensive language services has also resulted in the state being able to track and document associated costs. For example, Washington’s current contract for interpreter services runs for two years and costs the state $24 million. The state’s LEP Program Manager estimated the cost of providing written translations for languages beyond the seven that are supplied by the state ranges between $50,000 – $70,000 per month.(6) State officials noted that while this might seem costly, they believe it is an essential investment to ensure that limited English proficiency individuals have equal access to programs.

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Developing Language Services in New Immigrant Destinations

Raleigh and Sedalia are not as experienced serving LEP populations as the other sites. Although the number of LEP applicants in Raleigh and Sedalia is lower and the language diversity is smaller than other study sites, immigration is on the rise and the LEP share of the caseload is growing. Raleigh has large numbers of recently arrived immigrants from Mexico and Central America and the city is also becoming a new refugee destination. The Spanish speaking population in Sedalia has also increased rapidly over the last decade; most are immigrants from Mexico and have migrated for work opportunities, primarily in the city’s meat-processing industry. There is also a small, but growing, Ukrainian community in Sedalia. Overall, however, limited English speakers still comprise only a small share of the total applicant pool for public benefits in both sites, and there is limited bilingual capacity — either in-house agency staff or individuals in the community whose services could be contracted — to perform translation and interpretation services.

Raleigh, North Carolina

Spanish-speakers comprise the overwhelming share of the limited English proficient caseload in Raleigh. Although the city has become home to an increasing number of refugees, other language speakers make up only a small share of limited English proficient applicants. This has made it difficult for the welfare agency to justify expenses of in-house or contract translators for these applicants. As a result, the primary methods of providing language services differ starkly for Spanish-speaking and non-Spanish-speaking individuals.

For Spanish-speaking LEP individuals, the welfare agency hired a number of new bilingual receptionists and eligibility workers, placing them in areas where they are most needed — for example, the public health clinic. There are Spanish-speaking receptionists at the front desk for handling food stamp and Medicaid/SCHIP applications in the main social services building, as well as in the building housing the public health clinics.

As of Summer 2001, there was greater capacity to provide language assistance to Medicaid/SCHIP applicants than either TANF/FSP/Medicaid or food stamp-only applicants. At the public health clinic, the place where most SCHIP/Medicaid applications in Raleigh are taken, there were sufficient numbers of Spanish-speaking eligibility workers — as well as a pool of agency-hired interpreters. At the main welfare office, food stamp-only and Medicaid/SCHIP eligibility determination interviews were held for Spanish speaking applicants only two days per week, at which time Spanish-speaking eligibility workers conducted eligibility determination interviews. For TANF applicants, there was only one Spanish language interpreter — a temporary employee — located at the main welfare office to provide interpretation services. Wait times for this interpreter could run up to two weeks, although waits of only a few days were more common.(7) Bilingual staff were hired since our visit and, as of April 2002, there were sufficient bilingual staff to hold eligibility interviews five days a week for Medicaid/SCHIP and food stamp-only cases.

For those who are not proficient in English or Spanish, there is no agency-based language assistance. If these applicants are refugees, they generally rely on family or friends. The refugee resettlement agency had plans to increase its language capacity by hiring an interpreter coordinator and setting up an interpreter pool in the Raleigh area. It was expected that interpreters would be paid on an hourly basis for all agency appointments scheduled through the interpreter coordinator. At the time of our visits, however, applicants speaking languages other than Spanish relied heavily on the language assistance of family or friends.

Sedalia, Missouri

When Spanish-speaking immigrants first started arriving in Sedalia in the late 1990s, there was very little bilingual language capacity within public agencies. The human service agency initially hired an interpreter to provide language services once a week, but the contract was subsequently discontinued due to underutilization. Due to the lack of bilingual staff, the welfare agency relies on a mix of interpretation services, all of which are based outside the agency.(8) These include local churches, a community-based organization, and applicants’ friends and families. In contrast, both the public hospital and health center, which receive a much higher volume of limited English speakers than the welfare office, have hired a bilingual Spanish speaking staff person to help applicants fill out and submit Medicaid and/or SCHIP applications.

Human service agency staff noted that they rarely need to contact interpreters because limited English-speaking applicants know the agency does not have interpreters and therefore bring their own interpreter to the office. For example, many Spanish-speaking applicants are helped by a state-funded, full-time bilingual application assistant housed at a local CBO. The smaller and more recently settled Ukrainian population draws upon family and members within their community to accompany applicants on visits to the welfare office. Although funding for contracted interpreter services is still available, agency staff reported that they have found the current informal arrangements to be more efficient and satisfactory. Finally, while eligibility staff can access a private language line as a last resort, virtually none did so — citing the same logistical and financial constraints as workers in other sites.

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Based on discussions with program staff, administrators, advocates and applicants, there is no one-size-fits-all approach to providing language services. Differences in the size and diversity of the immigrant and LEP populations in the study sites have resulted in different responses by human service agencies. Even within a given site, differences in the sizes of various LEP populations have motivated welfare agencies to rely on varying language access tools and strategies as they try to balance demand for communication with LEP applicants with the supply of agency resources and personnel.

For the most dominant language group in each site, the sites found it useful to have some in-house staff available to provide interpretation. For less common language groups, however, this approach may not be cost-effective and may be difficult to administer. Therefore, relying on alternative forms of language assistance to accommodate less-common languages is reasonable and perhaps even preferable. However, multi-tiered approaches may become simply patchwork attempts at filling gaps in language services by whatever means happen to be available at the time. In such situations, LEP applicants may not receive the interpretation and translation services intended by stated policies unless a commitment is made to fully implement each tier and educate staff on the sequence of priorities.

In all of our sites, LEP Spanish speaking individuals are the most likely to receive adequate language services because agency staff are more likely to speak Spanish than any other language and there is a stronger community and agency infrastructure for handling the language needs of these applicants. However, in new settlement areas, such as Sedalia or Raleigh, this infrastructure is still relatively undeveloped. Speakers of less-common languages have even more mixed experiences. Those who are refugees often receive significant assistance navigating the application process from resettlement agencies. In Dallas and New York this extra help for refugees is reinforced by specialized agency offices or units that exclusively or primarily serve refugees.

Regardless of the site, sustained growth in the immigrant population and the increase in the number of languages spoken by immigrants present significant challenges to public agencies. Localities that traditionally receive large numbers of immigrants and have already developed strategies for handling their needs are trying to keep up with the extra demands posed by the large increase in the number of languages spoken by the most recent immigrants. On the other hand, localities that have only recently become home to significant numbers of immigrants have had to determine how to meet the needs of these newcomers and develop language assistance systems largely from scratch.

Because of the continually changing composition of the immigrant population across our sites, simply adding new bilingual staff to match each new immigrant wave may be neither possible nor prudent. Whatever language strategy localities embrace, they also need to build in some degree of flexibility to keep up with changing language needs. While providing language services on a contract basis may help mitigate this problem, it also may reduce the ability of public agencies to monitor the overall quality of the language services provided to LEP applicants.

Many of the study sites focus on providing language assistance at key stages of the application process which require the most interpersonal contact (i.e., during initial reception and eligibility interviews). Less visible but still critical aspects of the application process, including the provision of translated written material and telephone interpretation services are often overlooked or inadequately addressed components of language access strategies.

Finally, the findings in this study indicate that it is important to view language access strategies used in the administration of public benefit programs within the context of the application processes for these programs. The more complex and involved the application process, the greater the challenge for providing language assistance at each stage in the process and the greater the likelihood that language difficulties would lead to miscommunications, incorrect determinations or terminated applications. Simplifying application processes where possible and making language assistance systematically available at every stage in the application process appears to improve communication and processing of applications by individuals with limited English proficiency.

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Endnotes

1.  Raleigh has no formal policy to compensate bilingual staff, but program administrators noted that language skills are sometimes substituted for experience and/or education, thereby occasionally providing additional compensation for bilingual staff.

2.  As of Spring 2002, the Human Resources Agency in New York City noted that it was contracting for on-call, on-site interpreters in its Job Centers (i.e., local TANF offices.)

3.  In New York City, "Job Centers" (i.e., welfare offices) are responsible for application intake and ongoing services for TANF/FSP/Medicaid clients (see Chapter 3 for further details).

4.  Spanish-speaking LEP applicants may also opt to apply for benefits at these LEP-targeted offices but are not required to do so. Given the comparatively high demand for and supply of Spanish-speaking bilingual staff, there is not the same need to adopt the targeted approach for the Spanish-speaking LEP population.

5.  In September 2001, soon after our interviews, the refugee units in Dallas and other major Texas cities were disbanded when a central call center for application intake for new refugees was established in Austin, the state capital.

6.  Office of Civil Rights (OCR) Update, Summer 2000. http://www.hhs.gov/ocr/newsletter/supg9.html , 7/02/2002.

7.  Spanish-speaking employment counselors were also on hand to provide interpretation services for eligibility interviews on a more limited basis.

8.  There are two Spanish-speaking child welfare workers in the welfare office but they are not used as interpreters during public assistance application interviews.


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