Language Needs Assessment Methodology
Virginia Department of Health,
2016 Language Needs Assessment Report
Executive Summary
This Virginia Department of Health, 2016 Language Needs Assessment Report captures limited English proficiency (LEP) population data unique to Virginia’s 35 local health districts from 2013 U.S. Census estimates and uses 2014 data from the Virginia Department of Education and WebVision. The report identifies district LEP populations and outlines recommendations to consider as each district reviews its plan of action to address local language barriers and increase health care quality to all LEP patients while meeting all federal requirements. The report, conducted by the Virginia Department of Health’s (VDH) Office of Health Equity (OHE,) provides highlights governing LEP guidelines and addresses recommendations for future analysis.
Legal Background:
In addressing the needs of LEP populations, the guidelines listed below are mandated by federal policies, which require Virginia’s health districts to grant access to language services for federally funded health care services that the districts provide.
- Title VI of the Civil Rights Act of 1964 prohibits recipients of federal funds from discriminating against individuals on the basis of race, color, or national origin. The courts have applied this statute to protect national origin minorities who are LEP.
- Executive Order 13166 issued on August 11, 2000, requires every federal agency providing financial assistance to non-federal entities to publish guidance on how their recipients can offer meaningful access to LEP persons and thus comply with Title VI regulations.
Process:
In completing this 2016 Language Needs Assessment Report, a review of four factors is included. The report’s recommendations are framed for each of Virginia’s 35 health districts. Descriptions of the four factors are listed:
- The number or proportion of LEP residents within this district: This factor reflects two data sources incorporated by VDH:
- The US Census 2010 – 2013 American Community Survey (ACS) which is a nationwide survey. The ACS collects and produces population, language and housing information every year.
- DOE data on Virginia’s student LEP participants in the 2004-2014 English as a Second Language (ESL) program. ESL is a Virginia public school program designed to help LEP students learn English as a part of their daily school curriculum.
- The frequency with which LEP individuals come into contact with VDH programs. This factor accumulates all district patient visits, also termed encounters, (total encounters and unduplicated patients) within a district calculated by the VDH Web Vision system. Web Vision tracks detailed district statistics to include: patient information, patient encounters and patient primary language.
- The nature and importance of the program, activity or service provided by the recipient (VDH) to its beneficiaries. This factor asks districts to consider the importance and urgency of district health care services delivered to LEP patients. If a district service is deemed important and urgent, immediate language services should be provided to the LEP patient. If a district service is important, but not urgent, and language services are needed, service can be delayed for a reasonable period of time.
- The resources available to the grantee/recipient (VDH) and the costs of interpretation/ translation services. This factor addresses district resources and the costs that would be imposed to comply with Title VI. Local health districts must carefully explore the most cost-effective means of delivering competent and accurate language services based on available resources. In order to assist local health districts with compliance, VDH contracted with Propio Language Services in 2012 to provide districts with cost-effective telephonic interpretation and translation services. The local health district’s 2014 telephonic [i] usage data, which includes detailed call statistics has been included in the district’s report to inform them of their utilization of telephonic interpretation services. These costs do not represent all interpretation and translation costs as a number of health districts have bilingual staff and some engage in-person interpreters on a contractual basis to better communicate with their patients.
LEP Requirements: The 2016 Language Needs Assessment Report’s recommendations also reflect the following minimum LEP requirements:
- 500 LEP patient encounters in a language for on-site interpretation in that language; when a district experiences 500 local LEP encounters specific to one language, an on-site interpreter is recommended for that specific language at the district.
- 5% of all patient encounters or 1000 LEP patient encounters in a language for translation of vital documents in that language. The translation of primary documents for any foreign language is recommended when a district experiences 5% of all patient encounter or 1000 LEP patient encounters of a specific language, whichever is less.
- This requirement is established by the Department of Health and Human Services, and documented in the “Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, 2003.”
VDH LEP Patient Encounters:
The 2016 Language Needs Assessment Report provides a summary of languages encountered by each health district. The report covers analyses on 2004-2014 data sets. During the 2014 reporting year, VDH reported the following:
- 45,493 unduplicated LEP patients
- 298,430 LEP patient encounters
- 298,430 unduplicated English-speaking patients
- 589,564 English-speaking encounters.
- The top ten non-English languages encountered were: Spanish, Arabic, Nepali, Vietnamese, Korean, Urdu, Farsi, Mandarin, Amharic, and French.
This report shows a marked decrease in total numbers of unduplicated LEP patients and LEP encounters; however the proportion of patients served as LEP has increased from 2008 to 2014.
VDH Language Services Usage/Vendor: In order to help health districts comply with culturally and linguistically appropriate health care services (CLAS) requirement, VDH contracts with a company that provides telephone interpretation and translation by trained and certified professionals in a number of languages. During 2013-2014 VDH utilized the language services for the following:
- Interpretation calls: 16,235
- Total minutes of calls: 216,393
VDH translated documents can be found on our website at www.vdh.virginia.gov/omhhe/clas/. Each year VDH contracts with a leading provider of professional, on-demand, over the phone and videoconference access language interpretation for business, medical, and government organizations. In 2016, Propio offers interpretation services for more than 100 languages with services available to districts.
VDH Highlights:
The 2016 Language Needs Assessment Report reflects that the language needs of Virginia’s 35 health districts vary dramatically. While some districts have very few language needs, many districts face the challenge of providing for numerous LEP populations. The recommendations identified in the report comply with Title VI and LEP requirements.
- Virginia health districts served patients who spoke nearly 100 different languages in 2013.
- The top 10 non-English languages encountered were: Spanish, Arabic, Nepali, Vietnamese, Korean, Urdu, Farsi, Mandarin, Amharic, and French
- The urban district serving the greatest patient language diversity was Fairfax, while Thomas Jefferson Health District showed the greatest rural language diversity.
- Fairfax is the most linguistically diverse district having served 85 different languages.
- Thomas Jefferson Health District utilized the telephonic translation services to provide more than 1,325 calls and linguistically serve more 20 than languages in 2014.
- Fairfax Health District has 153,425 LEP individual residents, comprising 15% of the total district population, according to 2013 estimates.
VDH Recommendations:
The 2016 report includes recommendations for onsite interpretation and/or bilingual staff and written translation of vital documents for a specific language for nine health districts italicized in the chart below. A summary of all of the recommendations follow:
(see our Translation and Interpretation Recommendations page for more information).
HEALTH DISTRICTS | 2016 ONSITE INTERPRETATION BILINGUAL STAFF | 2016 WRITTEN TRANSLATION OF “VITAL DOCUMENTS” |
Alexandria | Spanish | Spanish |
Arlington | Spanish, Mongolian, Arabic | Spanish |
Central Shenandoah | Spanish | Spanish |
Chesterfield | Spanish | Spanish |
Chickahominy | Spanish | Spanish |
Crater | Spanish | Spanish |
Eastern Shore | Spanish | Spanish |
Fairfax | Spanish, Arabic, Korean, Vietnamese, Farsi, Urdu, Mandarin, Amharic, Somali | Spanish, Arabic, Korean, Vietnamese, Farsi, Urdu, Mandarin, Amharic |
Henrico | Spanish, Arabic, Nepali | Spanish |
Lord Fairfax | Spanish | Spanish |
Loudoun | Spanish | Spanish |
Peninsula | Spanish, Burmese | Spanish |
Pittsylvania-Danville | Spanish | |
Prince William | Spanish | Spanish |
Rappahannock | Spanish | Spanish |
Rappahannock/Rapidan | Spanish | Spanish |
Richmond | Spanish | Spanish |
Roanoke | Spanish, Burmese | Spanish, Burmese |
Thomas Jefferson | Spanish, Burmese | |
Virginia Beach | Spanish | Spanish |
Strikethrough – 2012 Recommendation No Longer Required | ||
Italicized – 2016 New Recommendations | ||
Note: Health Districts not listed had no recommendations. | ||
The 2016 Language Needs Assessment Report defines “Vital Documents” as follows:
- Consent and complaint forms
- Notices advising LEP persons of free language assistance
- Intake forms with potential for important health consequences, ex.: Consent to Treat Form
- Written tests that do not assess English language competency, but test competency for a particular license, job or skill for which knowing English is not required
- Written notices of eligibility criteria, rights, denial, loss, or decreases in benefits or services
- Applications to participate in a recipient’s program or activity or to receive recipient benefits or services
- Actions affecting parental custody or child support, and other hearings
Cultural & Health Literacy Resources
In order to assist VDH in meeting its CLAS needs, the report also notes numerous resources available to assist VDH in providing services to LEP populations. OHE manages various resources created specifically for district utilization. The following are the most frequently used resources.
- www.CLASActVirginia.org – A comprehensive informational website. The vast resources available include:
- LEP policies and guidelines, statistics, district documents,
- VDH patient handouts available in various languages, and
- audio files for frequently used phrases in multiple languages and much more
- Language Identification Poster – VDH has designed a poster that informs patients in 35 languages of their rights to a trained interpreter at no cost. Copies of this poster should be displayed at all offices of the health district and, as appropriate, in multiple locations within offices. This poster is available online at
http://www.vdh.state.va.us/healthpolicy/healthequity/documents/8x11languagecard.pdf
- Navigating the US Healthcare System – Materials designed to assist new immigrants, refugees and migrants to understand how to obtain health care services. Educational materials are available in Spanish, Arabic, Vietnamese, and Russian which explain the U.S. Healthcare System with sensitivity to cultural differences. Toolkit materials include a Newcomer’s Guide, a Resource Guide, and teaching materials. A new chapter on the Affordable Care Act and illustrations for improved readability were added in 2016. These materials and a video on how to use them are housed on the Navigating Health. More information is available at:
http://www.vdh.state.va.us/healthpolicy/healthequity/navigating-healthcare.htm
Partnership to Address Needs of Medical Interpreters:
At the 2009 Virginia Health Equity Conference, participants identified a need to develop a Medical Interpretation collaborative to address a wide range of topics germane to serving the LEP populations. To address this need, OHE is working with medical interpreter stakeholders to establish a statewide medical interpreter’s network that will identify and address emergent needs of serving Virginia’s LEP population.
Interpreter Database:
Health districts are advised to use medical interpreters who have been assessed for proficiency in the target language and English and trained in the provision of professional, ethical medical interpretation. OHE has established a searchable database to help identify interpreters of specific languages in different parts of Virginia. Qualified interpreters are encouraged to register. Applicants for inclusion must have 40 hours of training in a curriculum that conforms with the standards of the National Council of Interpreting in Healthcare and more than 40 hours of documented experience in medical interpreting. This database can be found at: https://www.vdh.virginia.gov/OMHHE/healthequity/MID/Home
Limitations of Informational Sources:
We acknowledge that there are limitations in the materials used to describe the populations and needs in our health districts. The census and ACS numbers cited are somewhat out of date but they are the most recent numbers available. The LNA identifies trends which we believe will be of value in planning.
The American Community Survey lumps together many languages which makes discerning the numbers and languages of some populations challenging. As an example, Virginia has 15,522 residents who report that they speak English “less than well” who are described only as “speakers of African languages” by the ACS. Virginia has welcomed many who emigrated from Africa and at times speakers of Amharic, Tigrinya, Swahili, Somali, Kinyarwanda, and Kirundi have made up significant numbers of health department clients. Similarly the ACS reports 22,901 speakers of Chinese but provides no specificity as to the number of individuals who speak Mandarin, Cantonese, Wu, etc.
Information from the Department of Education identifies LEP children in our area but not the adults. Inferences can be made about population change that is more up to date than the census. Information on the literacy level of adults in our communities, including the limited English speaking population, is not available. While overall literacy information (12% of adults lack prose literacy, 29% struggle with literacy and numeracy) and educational attainment information (in the ACS) are available; information on the literacy level of different LEP populations is not. Links to country reports on populations who have resettled in the United States are identified on the CLAS Act Virginia website.
Population change:
Many localities see population shifts and changes in languages encountered. Ongoing outreach and strong lines of communication are required to identify and meet local needs. Refugees are a special class of immigrants who come to our communities through agreements with the US Department of State. Each new arrival receives a health screening at their local health department. Numbers and ethnicities change each year so programs involved in refugee screening benefit from close communication with area resettlement agencies and the VDH Newcomer Health Program. In 2016, twenty health districts responded to the needs of recently arrived refugees.
Conclusion:
The goal of the 2016 Language Needs Assessment Report is to provide a resource that enables better understanding of local district LEP populations and resources necessary to meet their needs. We recognize that this report relies very heavily on a few data sources and does not address all district level challenges or resources, e.g. number of bilingual staff, languages spoken. To address this limitation, our goal is that in future reports OHE will explore various methods such as local interviews, surveys, etc., to integrate district specific LEP activities and needs identified by clients and partners. Also, future editions will examine language needs in environmental health programs (e.g. restaurants in which owners do not speak English.)
Nonetheless, the 2016 Language Needs Assessment is an informative resource to guide policy decision-making and enable health districts to better serve their LEP patients. Therefore, the report serves as a starting point from which each district can make more detailed and locally focused evaluation of its language needs, recognizing that those needs may be highly variable by year and locality.
For additional information regarding this report: call 804-864-7435, or http://www.vdh.virginia.gov/ohpp/clasact/LanguageProfile.aspx or contact: OHE, 109 Governor Street, Richmond, VA 23219.
[i] Propio in most districts, Voiance Language Services and Language Services in Arlington,