Linguistic and Cultural Competency Guidelines and Assurances

These Linguistic and Cultural Competency Guidelines and Assurance (LCC Guidelines) are attached to the Community Services Agreement (Agreement) and incorporated into it.

If you have any questions or need further assistance, please contact Christine Hammond, IDHS, via email.

Printable Version: Linguistic & Cultural Competency Guidelines and Assurances (pdf)



1.1. Introduction.  The purpose of these LCC Guidelines is to improve access to culturally competent programs, services, and activities for Limited English Proficient (LEP) customers, persons who are hard of hearing or Deaf, and persons with low literacy (collectively, the Goal). LEP Customers, as used herein, includes LEP Customers, persons who are hard of hearing or Deaf, and persons with low literacy.

1.2. Linguistic and Cultural Competency Mandate.  These LCC Guidelines were developed because the State of Illinois must comply with the Constitution of the United States, Title VI of the Civil Rights Act of 1964, Americans with Disabilities Act of 1990, Americans with Disabilities Act Amendments Act of 2008, Illinois Human Rights Act, and the 1970 Constitution of the State of Illinois and any laws, regulations or orders, federal or state, which prohibit discrimination on the grounds of race, sex, color, religion, national origin, age, ancestry, marital status, disability, or the inability to speak or comprehend the English language.

1.3. Assessment Purpose.  These LCC Guidelines require the submission of an assessment, as described below. The assessment is an initial step to complete compliance, followed by using the assessment to develop and institute an implementation plan. It is expected that within two years complete implementation will occur, with complete requirements. For more information, visit (this website also has available training resources and examples).


Key Concepts

2.1. Cultural Competence.  A set of behaviors, attitudes and policies in a system, agency or among professionals that affect cross-cultural work, evolving over time.

2.2. Individual Cultural Competence.  Acquisition of the values, knowledge, skills and attributes that allows an individual to work appropriately in cross-cultural situations.

2.3. Organizational Cultural Competence.  Systems and organizations approve, and in some cases mandate, the incorporation of cultural knowledge into policymaking, infrastructure and practice. An example of an LEP practice would include: requiring written material translated, adapted, and or provided in alternative formats based on needs and preferences of the populations served.

2.4. Language Access.Assuring language access means providing language assistance services, including bilingual personnel and interpreter services, at no cost to each LEP customer, at key points of contact, in a timely manner. Interpretation and translation services must comply with all relevant federal, state and local mandates governing language access. Consumers must engage in evaluation of language access and other communication to ensure quality and satisfaction. Importantly, Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color or national origin including actions that delay, deny, or provide different quality services to a particular individual or group of individuals. See Civil Rights Act of 1964, Pub. L. 88-352, July 2, 1964, 78 Stat. 241, as amended.

2.5. Meaningful Access.  Providers and their subcontractors, providing services subject to 7 C.F.R. § 272.4(b) are required to take reasonable steps to ensure meaningful access to their services and programs by LEP Customers. Compliance involves the balancing of four factors: 1) the number and proportion of eligible LEP Customers, 2) the frequency of contact with LEP Customers, 3) the importance or impact of the contact upon the lives of the person(s) served, and 4) the resources available to the organization. This four-factor analysis (LEP Assessment) may be applied to the different types of programs or activities the Provider provides to determine the level of language assistance measures sufficient to assure full compliance or to demonstrate reasonable efforts.



3.1. Assessment Submission.  The Provider shall submit to the State Agency its LEP Assessment by April 1, 2014.

3.2. Assessment Detail.  The Assessment must include the following:

  1. Data on the race, ethnicity and primary spoken language of the customers served by the agency;
  2. Identification of the number of bilingual staff, their language(s), and job description of those who facilitate access to and the provision of agency services; and
  3. Any Provider policy statements that assure compliance with federal and state law regarding equal access and service delivery to LEP Customers.

Assessment Template

Important Links

American Community Survey 2006-2010 - Illinois


LEP Plan Template

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LEP Best Practices

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Next year's Proposed LEP Contract Guideline for LCC for IDHS

FAQ's Section

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