VI. Operational Plan
A. Language Access Roles and Assignments
Language Access Coordinator
The Language Access Coordinator ("the Coordinator") for the Department of State is responsible for drafting and maintaining the Language Access Plan. The Coordinator is responsible for Plan implementation and serves as a resource to the bureaus to help resolve issues that arise related to language access. The Coordinator is designated by the Department's Office of Policy, and works under the direction of the Governor's Secretary of Policy and the Secretary of the Commonwealth.
The Language Access Coordinator's responsibilities include:
- Provide training to Department staff.
- Track and resolve issues related to language services.
- Respond to language services complaints.
- Conduct regular data review.
- Conduct outreach.
- Collect feedback from community organizations.
Each of the Department's bureaus that primarily provides services to the public has a language access liaison. Those bureaus are:
- Bureau of Election Services and Notaries
- Bureau of Election Security and Technology
- Bureau of Campaign Finance and Civic Engagement
- Bureau of Corporations and Charitable Organizations (BCCO)
- Bureau of Enforcement and Investigation (BEI)
- Bureau of Professional and Occupational Affairs (BPOA)
- State Athletic Commission (SAC)
Liaisons are responsible for guiding and tracking the implementation of the Language Access Plan at the bureau level, and communicating issues and challenges related to implementation to the Department Coordinator. The bureau liaisons' responsibilities include:
- Be knowledgeable about the Language Access Plan and language services.
- Arrange training for bureau staff.
- Manage the bureau's document inventory and review process.
- Bring issues related to language services to the Coordinator's attention.
- Collect and report data to the Coordinator.
B. Training for Department Staff
The Department will routinely provide training to staff related to language access policies and procedures. The training is offered to new employees during onboarding and offered to existing employees at least every two years.
The Language Access Coordinator offers training on the following topics:
- The Language Access Plan and its application.
- Telephone interpretation.
- Tips for working with interpreters.
- Plain language principles.
- Requesting document translation.
- Requesting in-person interpretation.
If additional training is needed, the Coordinator will work to accommodate those requests.
C. Language Interpretation
As a best practice and to safeguard against inaccurate and incomplete interpretation, professional interpreters should be used via the statewide contracts, rather than allowing the client to use a friend or family member as an interpreter. Children should never be used as interpreters. Multilingual staff may provide in-language services, but they should not be asked to interpret.
For administrative hearings, such as hearings related to professional licensing, the Department of State uses certified or otherwise qualified interpreters registered with the Administrative Office of the Pennsylvania Courts (AOPC) whenever possible.
The Language Access Coordinator provides instructions to Department staff for accessing interpretation services. Those instructions outline the steps staff must take to avoid errors and delays. Any concerns related to interpretation services should be reported to the Coordinator.
The Department provides telephone interpreting as needed at no cost to clients. All staff receive training on the use of telephone interpretation services.
It is common for clients who are deaf or hard of hearing to communicate over the phone using assistive equipment and/or a telephone relay service, available at no cost by dialing 711. Department of State staff are trained to respond to such calls.
The Department provides in-person interpreters for in-person interactions as needed at no cost to the client. Staff should communicate to clients that it takes a minimum of two days to arrange for an in-person interpreter. For brief, unscheduled interactions with persons who are limited English proficient, it may be appropriate to communicate using telephone interpretation over speaker phone. However, Department staff must offer to provide an in-person interpreter when the client and staff cannot communicate effectively using telephone interpretation, or at the client's request.
For persons who use sign language, the Department will arrange for in-person interpretation for in-person interactions when the client and Department staff cannot communicate effectively, or at the client's request.
D. Document Translation
The Language Access Coordinator works with the bureau liaisons to conduct a semi-annual inventory and assessment of the documents each bureau makes available to the public. The assessment will determine how each document will be prioritized for translation.
The Department prioritizes the translation of vital documents, which are documents that clients must understand in order to access Department services or are required by law. Documents that are considered "vital" may include:
- Application materials.
- Complaint forms.
- Forms that include an acknowledgment, release, or waiver.
- Notices concerning program eligibility, program rules, or notices of termination.
- Notices about the availability of language services.
In addition, documents are reviewed for translation based on the following four factors:
- The number and proportion of LEP persons served or encountered.
- The frequency with which LEP individuals come into contact with the program or service.
- The importance of the document and program to the LEP persons' lives.
- The resources available to the program and costs associated with translation.
A document may be translated in response to a request from an individual, depending on the availability of Department resources. The Department will acknowledge all requests for translation within five (5) business days and respond to requests within a reasonable amount of time.
In some cases, when a document has not been translated, taglines may be attached to the document. Taglines are statements printed in languages other than English that alert clients to the availability of free language services.
Written document translation is performed by qualified translators using the statewide contracts for translation services. Multilingual staff should not be used to translate written documents. The Language Access Coordinator will provide written instructions to Department staff for requesting document translations. Those instructions outline the steps that should be taken to assure the quality of translations, including verification by multiple vendors, and community review. Any concerns related to the quality of translations should be reported to the Coordinator.
E. Plain Language
Before any new document or other media is made available to the public or submitted for translation into another language, it must be reviewed for plain language. The plain language review ensures that public facing documents are clear, organized and concise, using common words and short sentences. The Language Access Coordinator provides instructions for Department staff to follow when conducting a plain language review. Department staff who have been trained in plain language principles may conduct the review and may consult with the Coordinator and the Office of Press and Communications for assistance.
The semi-annual document inventory mentioned in section VI.B above includes a plain language review. When documents are assessed for translation priority, the bureau liaison should make note of which documents need to be drafted into plain language, regardless of whether they will be translated.
F. Web Content
Web content refers to information the Department makes available on the internet, including written text, video recording, and audio recording. It includes content available on the Department website, other Commonwealth sites, and social media platforms.
The Department's Office of Press and Communications and the Language Access Coordinator will review Department-produced web content to ensure it is accessible for people who are LEP or deaf or hard of hearing.
In general, the determination to make web content available in other languages is made using the same four-factor analysis mentioned in section VI.D above.
Written Web Content
After the adoption of this Plan, all new written content created by the Department must be reviewed for plain language before it is published online. This helps optimize machine translations produced by web browser or web page add-ons, such as Google Translate.
Documents and Other Media
When documents or other media published online are available in other languages, the page where the English media appears will prominently display links to the media in other languages.
The Department of State includes closed captions in English for all videos it produces, and may translate the captions into other languages, based on the result of the four-factor analysis listed above.
A web application is a program that is stored on a remote server and delivered over the internet through a web browser. The Department may translate web applications in full or in part as necessary, with the determination made according to the four-factor analysis.
The Department of State website includes a page dedicated to language access. Key components of this Plan will be included in the web page contents so that they may be translated into other languages using the web page ad-on Google Translate. This Plan is also available on the page in its entirety.
The Department makes the following notices available to the public:
- Each page of the Department's website states that language services are available and provides a link to the Department's web page on language access.
- In each bureau that provides walk-in services, signs are posted in the most commonly used languages that interpreters are available.
- Community organizations are notified when this Plan is finalized and when it is updated.