Programs and Services

Limited English Proficiency Assistance

Polk County will make reasonable efforts to ensure county programs, services and activities, i.e., building plan reviews, indigent healthcare, veterans services are meaningfully accessible to those who do not speak English proficiently. These include:

• Identifying county employees who are fluent in languages in addition to English to act as translators whenever necessary
• Utilizing Google’s translator on all sites posted on the county website in order to allow individuals to translate information regarding programs and services into their language of choice.

To determine if or when alternate language usage is required for meaningful access, the county will assess the program, service or activity using the following four factors:

1. • The number or proportion of LEP persons eligible to be served or likely to be encountered by the county’s programs, services or activities
   • The frequency with which LEP individuals come in contact with these programs, services or activities
   • The nature and importance of the program, service or activity to people’s lives
   • The resources available to the county and the costs

Persons requiring special language services should contact Polk County’s Equal Opportunity Division, Fourth Floor, Polk County Administration Building, 330 W. Church St., Drawer CA05, Bartow, FL 33830 or call (863) 534-5901.

You will find the Limited English Proficiency Plan here.

Proactive Diversity Recruitment and Training Program
This program is a necessary and strategic response by the county to meet the demands of Polk’s diverse population and ensure that its workforce mirrors that population.

Office of Supplier Diversity
The Office of Supplier Diversity oversees the Women and Minority Business Enterprise program and ensures the utilization of women and minority vendors in with county contractual opportunities. This program also serves as an advocate for county agencies and the women and minority business community and holds educational seminars and training for business growth and development.

Limited English Proficiency Plan

Introduction
The purpose of the Polk County Limited English Proficiency (LEP) is to clarify our responsibilities as a recipient of federal financial assistance from the U.S. Department of Transportation (DOT) and implement a plan detailing our responsibilities to LEP persons, pursuant to Title VI of the Civil Rights Act of 1964. This LEP plan was prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 USC 2000d, et seq., and its implementing regulations provide that no person shall be subjected to discrimination on the basis of race, color or national origin under any program or activity that receives federal financial assistance. It also complies with Executive Order 13166 “Improving Access to Services for Persons with Limited English Proficiency,” reprinted at 65 FR 50121 (August 16, 2000), which directs each Federal agency that is subject to the requirements of Title VI to publish guidance for its respective recipients clarifying that obligation. Executive Order 13166 further directs that all such guidance documents be consistent with the compliance standards and framework detailed in the Department of Justice’s (DOJ’s) Policy Guidance entitled “Enforcement of Title VI of the Civil Rights Act of 1964 – National Origin Discrimination Against Persons with Limited English Proficiency” (See 65 FR 50123, August 16, 2000 DOJ’s General LEP Guidance). Different treatment based upon a person’s inability to speak, read, write or understand English may be a type of national origin discrimination.

It is the intent of the county that in providing language services to persons with limited English proficiency, the process achieves a balance that ensures meaningful access to programs and services, while not incurring undue burden on resources of the organization. A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write or understand English.

This plan details how the county identifies people who may need language assistance, the ways in which assistance may be provided, how the county did notify LEP persons that assistance is available and information for future plan updates.

Who is the plan intended to assist?
This Limited English Proficiency plan applies to individuals who do not speak English as their primary language, and who have a limited ability to read, speak, write or understand English. For example, the scope of the plan would not extend to the following:

• The hearing or visually impaired. Sign language, interpretation and braille text are accommodations provided under the Americans with Disabilities Act.
• Illiteracy. The inability to speak, read or write English and conditions that may trigger language assistance under Title VI are distinguished with a key factor. A LEP person cannot speak. read or write English, but primarily speaks, reads, or writes in a language other than English.

Four-Factor Analysis
To help determine the county’s extent of obligation to provide LEP services, the county follows the US Department of Transportation, four factor LEP analysis, which considers the following: 1) the number or proportion of LEP persons eligible in the county to be served, are likely to encounter a program, activity or service; 2) the frequency with which LEP individuals come in contact with a program; 3) the nature and importance of the program, activity or service provided to the LEP population; and 4) the resources available to the county, and overall cost to provide LEP assistance. A brief description of these considerations is provided in the following section.

The number or proportion of LEP persons, eligible to be served, or likely to encounter a Polk County program, activity or service
The county examined the US, Census Bureau‘s American community survey data and determined that approximately 18.9%, or 106,519 people in Polk County age five and older spoke a language other than English at home and 8%, or 45,055, stated they speak English less than very well. Hispanics comprise the largest non-English-speaking language group. There were 198,663 Hispanic/Latinos or 27.4% of the Polk County population in spoken language other than English at home and 6.6% of the population said they speak English less than very well.

The frequency with which LEP individuals come in contact with a Polk County program, activity or service
Polk County assesses the frequency at which staff help or could possibly have contact with LEP persons. This includes documenting phone inquiries and serving public meeting attendees.

The nature of importance of the program activity or service provided by Polk County to LEP community
It is our intent to educate the LEP community about our unified planning work program (PWP), transportation, improvement program (TIP), and Long Range Transportation Plan (LRTP). Based on data obtained from the census, we expect to likely come in contact with Spanish, German, Creole or French speakers with the Spanish community, being the largest population, and growing the fastest in Polk County.

The resources available to Polk County and overall cost to provide LEP Assistance

Polk County provides the following available resources that could be used for LEP Assistance:

• Identifying what staff and volunteer language interpreters are readily available.
• How much professional translation service would cost.
• Identifying which documents should be translated.
• Taking an inventory of available organizations that the county could partner with for outreach in translation efforts.
• Examining which financial and in-kind sources could be used to provide assistance and what level of staff training is needed.

Polk County will utilize current staff and volunteer language interpreters and/or translators as needed. Should need for additional translation or interpretation rise, the county could utilize language services available through www.serviceescape.com if necessary. Polk County could also use personal interpreter services through www.languageline.com.

The following materials are currently available in Spanish: Advisor brochure, Aging in Place and Transit infographic, 2035 Polk Mobility Vision Plan newsletter. Should the need to arise for additional translation services, the county will analyze cost and resources to provide LEP Assistance.

Polk County has identified the following community groups who could aid in outreach in translation efforts: the Puerto Rican/Hispanic Chamber of Commerce, the German-American Club of Lakeland, the French-American Business council of West Florida and the Haitian American Chamber of Commerce of Florida.

How to identify a LEP person who needs language
After analyzing the four factors, Polk County has developed the plan outlined in the LEP plan:

Staff will set up a sign-in sheet at sponsored workshops and/or conferences. The sign-in table will be staffed by our bilingual representative to greet and briefly speak to each attending to informally gauge the attendee’s ability to speak and understand English.

Staff will have the Census Bureau’s “I Speak” cards at the workshop or conference sign-in table. All staff may not be able to provide translation assistance at this meeting. The cards are an excellent tool to identify language needs for future meetings.

Language assistance measures
When an interpreter is needed in person or on the telephone, the county shall first determine what language is required. Polk County staff can provide Creole, German, Haitian, Hindi, Filipino, Spanish, and Vietnamese in formal verbal interpretation. Appendix B details which Polk County employees can be contacted for immediate translation service in a variety of languages. Staff may be able to assist with written communications and document translation request from LEP persons. Spanish teletypewriter (TTY) relay service is available through Florida Relay Service at (800) 955–8771

Staff has been provided with a “how to respond to a Spanish caller index card.” This index card will provide a simple phrase in Spanish for county staff to instruct a Spanish caller to hold while their call is being transferred to our bilingual transportation planner.

County staff training
Polk County staff are provided with the LEP plan and educated on procedures and services available. This information will also be part of the staff orientation process for new hires.

Providing notice of available language service to LEP persons
Polk County will post signs that language assistance is available to the public before public meetings. Our website is equipped with a language translator for Spanish, French, German and Creole. Staff will continue to monitor requests for additional languages and make modifications to this plan as needed.

Outreach techniques
For the strategies outlined in the Bill, if staff knows they will be presenting a topic that could be a potential importance to a LEP person, or staff will be hosting a meeting or a workshop in a geographic location with a non-concentration of LEP persons, meeting notices, flyers, advertisements and agendas will be printed in an alternative language, such as Spanish

When placing a general public meeting notice, staff will insert “un traductor del idioma Español estará disponsible.” This means “A Spanish translator will be available.” Or if not sure of the need, staff should insert, “Si usted necessitating la ayuda de traductor del idioma español, pot favor cominiquese con Mianne Nelson al teléfono (863) 534-6090, por lo menos 48 horas antes de la junta” which asks persons who need Spanish language assistance to make arrangements with the county within two days of the publication notice. Spanish-speaking staff, or a hired interpreter should be on hand at public meetings, intended for gathering public input on a topic or meeting location themes it appropriate.

Dissemination of the Polk County Limited English Proficiency plan
Any person, including social service, nonprofit and law-enforcement agencies and other community partners with Internet access will be able to access the plan. For those without personal Internet service, all Polk County libraries offer free Internet access.

Copies of the LEP plan are provided to the Florida Department of Transportation, Federal Highway Administration, the Federal Transit Administration, and any person or agency requesting a copy. Each county subrecipient is provided a copy and informed of the importance of providing language assistance. LEP persons may obtain copies/translations of the plan upon request by calling (863)534-6075.

Monitoring and updating the plan
At a minimum, Polk County will follow the title six program update schedule for the LEP plan. The questions listed below will be considered in updating the plan.

• How many LEP persons were encountered?
• Were their needs met?
• Has there been any change in the type of language where translation services are needed?
• Have the county’s available resources, such as technology, staff and financial costs changed. Has the county fulfilled the goals of the LEP plan?
• Were any complaints received?

Any questions or comments regarding this plan should be directed to Richard L. Bradford, Equal Opportunity Administrator, (863) 534-6075 or email richardbradford@polk-county.net

Proactive Diversity Recruitment and Training Program

This program is a necessary and strategic response by the county to meet the demands of Polk’s diverse population and ensure that its workforce mirrors that population.

Office of Supplier Diversity

The Office of Supplier Diversity oversees the Women and Minority Business Enterprise program and ensures the utilization of women and minority vendors in with county contractual opportunities. This program also serves as an advocate for county agencies and the women and minority business community and holds educational seminars and training for business growth and development.