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
- First Tier — On-site Bilingual Eligibility Staff. Under the LEP policy currently in effect, reception staff are supposed to immediately identify the language preference of applicants, generally using "I speak" palm cards. The policy mandates that once the appropriate language is identified, the applicant should be assigned to a bilingual eligibility worker who speaks the applicant’s primary language. This is considered the first — and best — line of attack because it allows for the most effective communication between LEP applicants and agency staff, and ensures that unqualified staff (e.g., clerks or security guards) are not used to interpret and explain agency rules.
- Second Tier — Agency Operated Phone Bank. Due to staffing constraints and the diversity of languages spoken, it may not be possible to match bilingual eligibility staff with applicants whose primary language is not English. The LEP policy explicitly puts a time limit on how long reception staff may look for appropriate-level bilingual staff for assistance with interpretation. If they cannot identify appropriate staff, they are supposed to turn to the HRA-staffed telephone language bank. This line provides interpretation services in Chinese, Russian, Spanish, and Vietnamese.
Discussions with TANF/FSP/Medicaid eligibility workers and reception staff suggest that this option is rarely used among the LEP applicants whose languages are presented on the language line. In fact, although HRA policy clearly states that workers are required to use the language bank when appropriate, discussions with staff indicated that this practice might not be common in the non-specialized Job Centers. For example, some staff and focus group participants indicated that limited English speakers are sometimes told to provide their own translators, even if they must resort to relying on their school-aged children, landlords, or building supervisors.
- Third Tier — Community Based Organizations. The next tier involves relying on community-based organizations that have indicated a willingness to provide the agency with interpretation services when in-house language resources are insufficient. Thus, if the internal HRA language line is not able to meet an applicant’s language needs, staff can turn to a special directory of community organizations to locate a volunteer interpreter.
Program administrators and staff noted that this referral system has not always worked well, in part because the CBO services are provided on an informal, ad-hoc basis. CBO staff who participated in this study raised concerns about the lack of compensation for these services, noting their limited resources and that their staff are often pulled from client meetings to interpret for the welfare agency. Eligibility workers, in turn, raised concerns about the variation in quality of interpretation services provided by CBO staff and the possibility of compromising client confidentiality when using them.
- Fourth Tier — Private Language Line. If all else fails and interpretation services cannot be obtained through the internal language line or a community based organization within a combined total of 15 minutes, the last strategy employed by staff is a private language line. The private language line can provide interpretation in 140 languages. This service is considered a strategy of last resort because it can be very expensive. As a result, few agency staff reported using the system.
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.