The Mayor’s Office of Immigrant Affairs, in collaboration with all City agencies, aims to bring Baltimore City to full compliance with language access law. But what does that mean?

To be in full compliance with language access law, the City of Baltimore must have the following components in place:

• A citywide language access plan:MIMA, in coordination with the Law Department, completed this step in 2018. 
• Four Factor Analysis: completed by all public-facing agencies, these analyses assess where an agency is at in terms of language access services. They should be updated every 10 years in accordance with federal standards..
• Agency Language Access Guidance Documents: The guidance document is completed by the language access liaison & serves as a roadmap for language access implementation within the agency.
• Agency staff training: 100% of City employees who interact with the public should have language access training, facilitated by MIMA. Identifying groups for these trainings and scheduling them is the responsibility of the language access liaisons. Training should be ongoing to account for staff turnover.
  • Training with MIMA is essential to ensure the agency or office has the necessary codes and established processes that are required when using interpretation and/or translation services.
• Translation of vital documents: All documents that are critical to access programs within an agency, affect continued participation in a program, or communicate termination of a service or those documents that are otherwise required by law must be translated and available in the City’s core languages. MIMA has a budget to facilitate translation of these documents over the next three years.
• Interpretation services: Limited English proficient individuals seeking services over the phone or in person must be offered interpretation services. MIMA oversees a citywide telephonic interpretation account, and trained employees gain no-cost access to this account. Interpretation services may also be needed for in-person events where a large number of speakers of another language are expected to attend.
• Outreach to limited English proficient residents: Agencies must notify LEP residents of language access services. Outreach can take many forms and includes but is not limited to signage offering interpretation in public facing locations, social media posts about services in multiple languages, working with cultural media sources (like TV and radio) and more targeted, community specific outreach like canvassing with flyers in multiple languages for a place-based project.

Once an agency has all of the above in place, the agency is considered a language access complaint! However, as programs are always changing, compliant agencies still maintain an ongoing relationship with MIMA to make updates and facilitate additional training as needed. The following page expands on two key items of this checklist: The Four Factor Analysis and Language Access Guidance Document.

What is the Four Factor Analysis?

This analysis serves as a baseline for planning and implementation of language access. While designed to be a flexible and fact-dependent standard, the starting point is an individualized assessment based on four key factors as established at the federal level.

These are the four factors and suggested information that supports the assessment:

Language Access Guidance Document:

While the City as a whole has a Language Access Plan, each agency is expected to have a Language Access Guidance Document. The purpose of this document is to create a roadmap for implementation, and since each agency is distinct, the specific steps towards implementation will vary by agency. Language Access Liaisons are responsible for completing this document with the support of MIMA’s Language Access Coordinator, and completion of the Guidance Document is the gateway to additional services like use of the citywide telephonic interpretation account and translation of vital documents, available at no cost to agencies through partnership with MIMA.

A Language Access Guidance Document has the following components:

• An explanation of existing language access services (if any) to serve as a baseline. This section is a brief summary of the Four Factor Analysis.
• A plan for implementation, which includes:
  • Identification of public-facing services that could be points of contact for LEP residents (e.g. call centers, service desks, outreach programs, etc.)
  • A plan for provision of oral interpretation services, often through telephonic interpretation but sometimes through in-person interpreters, for example, at community events
  • Training of staff who have contact with the public or are involved in program development so that language access becomes seamlessly integrated into agency’s day-to-day functions
  • Budgetary considerations that lie outside the services covered by MIMA
• An outreach plan to notify the public of available services through signage in public-facing City office or social media, for example
• A data management strategy, which details how an agency will track data on the number of LEP residents served

Language Access Liaisons receive training and have access to ongoing support as they complete the Guidance Document. A Guidance Document is crucial, as it will exist beyond any one staff member and helps MIMA understand the type of ongoing support that each agency needs.