UMRBA Language Accessibility Plan

Statement of Purpose

UMRBA is committed to supporting meaningful access to all UMRBA programs, services, and activities for individuals with limited English proficiency at no direct cost to those individuals.  UMRBA will provide services to individuals with limited English proficiency in a manner consistent with  applicable Federal civil rights statutes, regulations, and Executive Orders

The purpose of this Language Accessibility Plan is to identify potential barriers, actions for the removal of identified barriers, and the status of progress relative to planned actions.

UMRBA uses its Notice of Non-Discrimination, Public Participation Plan, and Standard Operating Procedures for its Quarterly and Other Public-Facing Meetings to guide this Language Accessibility Plan, and reviews adherence to UMRBA’s accessibility standards annually.

Domains of Accessibility

Community Integration and Attitudes

Community Integration and Attitudes barriers to accessibility include i) any barrier that prevents an individual from full participation in UMRBA’s programs, services, or activities and ii) preconceived opinions about persons with limited English proficiency.  Examples might include how persons are viewed and treated and whether input from persons with limited English proficiency are solicited and used.

Finances

Financial barriers include insufficient funding for services and supports. Examples include organizational financial security and funding for UMRBA programs, projects, and services.

Communication

Communication barriers include any absence of telecommunication devices that are used and/or the absence of material in language or format that is understood by persons with limited English proficiency.

Technology

Technology barriers are present when useful and available technology is not accessible to persons with limited English proficiency.

UMRBA Nondiscrimination Coordinator

The UMRBA Nondiscrimination Coordinator is Natalie Lenzen (nlenzen@umrba.org). Natalie Lenzen serves as UMRBA’s point-of-contact for any discrimination grievances and to coordinate UMRBA’s nondiscrimination policies, procedures, and activities. 

Planned Actions

Community Integration and Attitudes

1. Training UMRBA staff 
   1. On an annual basis, the UMRBA Operations Manager will receive training on policies and procedures on how to process and accommodate services to aid in UMRBA’s efforts to provide meaningful access to all UMRBA programs, services, and activities for individuals with limited English proficiency.  Following the training, the UMRBA Operations Manager will share insights gained with the full UMRBA staff team as well as any updates to UMRBA’s Accessibility Plan for Individuals with Limited English Proficiency.
   2. UMRBA will strive to hire staff with bilingual capabilities to assist in providing meaningful access to all UMRBA programs, services, and activities for individuals with limited English proficiency. 
   3. In the scoping phase of a potential new and “major” UMRBA program, project, or activity:
      1. UMRBA will employ the UMRBA Public Participation Plan to determine community engagement strategies and whether any strategies involve training with respect to potential community integration or attitude barriers to the participation of individuals with limited English proficiency. This includes evaluating and selecting the appropriate language services – e.g., translation (written) and interpretation (verbal) and for which language(s).
      2. If specific training strategies are identified, UMRBA staff will explore opportunities for training that meet the particular needs for removing or minimizing the potential community integration or attitude barriers to the participation of persons with limited English proficiency.
      3. UMRBA will first explore training strategy(ies) that are available at no or low cost to the Association.  If necessary, UMRBA will seek opportunities for financing the training strategy(ies) within the funding source for the program, project, or activity or seek additional funding. 
   4. As knowledge of barriers within UMRBA’s programs, projects, and activities are discovered, UMRBA staff will evaluate the specific barrier and identify and participate in the training necessary to address the barrier.  UMRBA will first explore training strategy(ies) that are available at no or low cost to the Association.  If necessary, UMRBA will seek opportunities for financing the training strategy(ies) within the funding source for the program, project, or activity or seek additional funding.
2. Addressing grievances
   1. UMRBA will include a statement acknowledging the use of translation or interpretation services and inviting individuals to contact the UMRBA Operations Manager with their review of the services and recommendations for improving future experiences.  The placement of the statement will be made orally at meetings and/or in writing in meeting materials, reports, or other documents. 
   2. Should UMRBA receive an informal or formal grievance of discrimination, UMRBA will evaluate the specific barrier to participation and will identify and have staff participate in the necessary training to address the barrier. 
3. Prominently broadcasting UMRBA Notice of Nondiscrimination
   1. Per UMRBA’s Public Participation Plan and Standard Operating Procedures for its Quarterly and Other Public-Facing Meetings, UMRBA will post its Notice of Nondiscrimination prominently on the UMRBA website and publications, including meeting notices and in meeting materials.
   2. If UMRBA knows of any participation of persons with limited English proficiency participating in a meeting or other activity, UMRBA, in consultation with the specific individual or community leader, will provide an oral statement at the beginning of the meeting regarding inclusive behavior and translation (written) and interpretation (oral) services.

Finances

1. Organizational resources
   1. On an ongoing basis, UMRBA will secure sufficient resources for certain technologies (i.e., UserWay) to enable language accessibility on UMRBA’s website.
   2. On an ongoing basis, UMRBA will secure sufficient resources for staff training (as provided above).  In some instances, staff training may be supported by a grant, cooperative agreement, or other contractual agreement.
   3. Upon request, UMRBA will explore financial means to support translation services to persons with limited English proficiency.  This will include requesting services that may be available using existing capacity within a UMRBA member state or federal liaison agency or exploring services that assist government or non-governmental organizations.  An example includes the Minnesota Department of Administration’s Cooperative Purchasing Venture.
2. Resources from grants, cooperative agreements, or other contractual agreements
   1. In the scoping phase of a potential new and major UMRBA program, project, or activity:
      1. UMRBA will employ the UMRBA Public Participation Plan to determine potential community engagement strategies and what, if any, strategies involve communications with persons with limited English proficiency.
      2. UMRBA will explore existing capabilities within partner organizations (funder, UMRBA member states, or implementing partners) that might be leveraged to implement the identified strategy(ies).
      3. UMRBA will estimate the costs of implementing the identified strategy(ies) and include the associated cost in the budget estimate in the application for a grant, cooperative agreement, or other activity.
      4. If necessary, UMRBA will seek additional funding sources to implement the identified strategy(ies). Explanatory note:  For the purposes of this document, a “major UMRBA program, project, or activity” involves an effort that shapes new or additional government resources or generates substantially new information.  An example includes strategic planning for state government-led interstate cooperation
   2. Upon request, or as requested, UMRBA will seek to modify a grant, cooperative agreement, or other contractual agreement to support the requested translation service(s).
3. Partner resources
   1. On a routine basis, UMRBA will ensure that UMRBA Board Members and Alternates are informed of UMRBA’s nondiscrimination responsibilities and associated resources and expenses.  UMRBA will explore and leverage existing programs and other activities offered by UMRBA member state agencies and federal agency partners to provide training, deliver translation services, or support another means for expanding accessibility to UMRBA’s programs, projects, and services.

Communication

1. UMRBA website 
   1. On an ongoing basis, UMRBA will integrate UserWay into the UMRBA website to provide translation services to enable language accessibility on UMRBA’s website.
2. UMRBA social media 
   1. UMRBA has an active social media presence, which is used relatively infrequently, for posting information about UMRBA publications, staff hirings, or other major announcements.  In its posts, UMRBA will provide a link to a UMRBA web page with information about how to request translation (written) or interpretation (oral) services.
3. UMRBA’s vital documents of interest
   1. UMRBA will place the text of UMRBA’s “vital” documents on the front web pages where those documents are linked so that they can be viewed in the languages available through UserWay. 
   2. Upon request, UMRBA will make available other “vital” documents of interest available in a requested language.  UMRBA will seek to secure a reputable translation service available in UMRBA member state agencies, a federal agency, or other non-governmental organization.  Explanatory note:  For the purposes of this document, a “vital document of interest” include the UMRBA Notice of Non-Discrimination, Public Participation Plan, and Standard Operating Procedures for its Quarterly and Other Public-Facing Meetings, Accessibility Plans for Individuals with Limited English Proficiency and Disabilities.
4. UMRBA’s quarterly meetings and other public meetings
   1. Per UMRBA’s Public Participation Plan and Standard Operating Procedures for its Quarterly and Other Public-Facing Meetings, UMRBA will post its Notice of Nondiscrimination prominently on the UMRBA website and publications, including meeting notices and in meeting materials.
   2. Upon request, UMRBA will provide oral interpretation services at no direct cost to those individuals.  UMRBA will seek to secure a reputable interpretation service available in UMRBA member state agencies, a federal agency, or other non-governmental organization.  UMRBA will consult with its member state agencies to evaluate the interpretation needs and the approaches for ensuring simultaneous oral interpretation, by qualified interpreters, of live proceedings.
   3. If UMRBA knows of any participation of persons with limited English proficiency participating in a meeting or other activity, UMRBA, in consultation with the specific individual or community leader, will provide an oral statement at the beginning of the meeting regarding inclusive behavior and translation services.

Technology

1. Researching cost-effective solutions
   1. On an annual basis, the UMRBA Operations Manager will research technologies that can assist in UMRBA’s commitment to supporting meaningful access to all UMRBA programs, services, and activities for individuals with limited English proficiency.  An example is incorporating UserWay onto UMRBA’s website.