Illinois Department of Human Services
Division of Family and Community Services
Bureau of Youth Intervention Services

Services for Homeless Youth RFA
Released March 1, 2014

Appendix 5 - Linguistic and Cultural Competence Guidelines

LINGUISTIC AND CULTURAL COMPETENCY GUIDELINES

The State of Illinois Linguistic and Cultural Competency Guidelines (LCC Guidelines) were developed as a mechanism for improving language and cultural accessibility and sensitivity in State-funded direct human services delivered by human service organizations that receive grants and contracts to serve the residents of the State of Illinois.

Linguistic and Cultural Competency Mandate: The Illinois Department of Human Services (the Agency) agrees to comply with the Constitution of the United States, Title VI of the Civil Rights Act of 1964, Americans with Disabilities Act of 1990, ADA Amendments Act of 2008, Illinois Human Rights Act, the 1970 Constitution of the State 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. The Agency will assure native language/interpreter services to the extent possible, when serving Limited English Proficient clients.

Vendor Assurance: The Vendor shall not discriminate on the basis of race, color, national origin, sexual orientation or sex in the performance of this contract. The Vendor shall also adhere to the principle of providing "meaningful access" to all LEP customers that the agency provides services to, in the performance of this contract. The Vendor ensures accountability of subcontractors and vendors by measurable objectives and performance monitoring at regular intervals for individuals from LEP and diverse cultural groups. Failure by the Vendor to carry out these requirements is a material breach of this contract, which may result in the termination of this contract or such other remedy, as the Agency deems appropriate.

Linguistic and Cultural Competence Definitions:

  • Cultural Competence: Cultural Competence is a set of behaviors, attitudes, and policies in a system, agency or among professionals that affect cross-cultural work. Cultural competence is a developmental process that evolves over an extended period. Both individuals and organizations are at various levels of awareness, knowledge and skills along the cultural competence continuum (adapted from Cross et al., 1989).
  • Cultural Competence: (Individual Level) At the individual level, this means acquisition of the values, knowledge, skills and attributes that will allow an individual to work appropriately in cross-cultural situations.
  • Cultural Competence: (Organizational Level) At the organization level, this means systems and organizations sanction, and in some cases mandate the incorporation of cultural knowledge into policymaking, infrastructure and practice. An example regarding limited English proficiency would include: Written materials are translated, adapted, and and/or provided in alternative formats based on needs and preferences of the populations served. Interpretation and translation services comply with all relevant Federal, State and local mandates governing language access and consumers are engaged in evaluation of language access and other communication to ensure for quality and satisfaction.
  • Language Access: Provision of 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. 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.
  • Meaningful Access: Subcontractors/Vendors, especially entities with a customer base that is more than five percent (5%) LEP, are required to take reasonable steps to ensure meaningful access to their services and programs by LEP persons. Compliance involves the balancing of four factors: 1) the number and proportion of eligible LEP customers, 2) the frequency of contact, 3) the importance or impact of the contact upon the lives of the person(s) served, and 4) the resources available to the organization. The organization will collect data on primary spoken language and, as appropriate, develop a plan to meet the needs of LEP customers.1

1 Illinois Department of Human Services Inter-Office. Draft Memorandum. 5-05.

Elements of a Comprehensive Linguistic and Cultural Competence Plan:

LINGUISTIC AND CULTURAL COMPETENCY GUIDELINES INDICATORS
1. Organizations should have a linguistic and cultural competence plan for the funded program(s) or for the organization as a whole that includes clear goals, outcomes, policies and/or procedures related to the provision of culturally and linguistically appropriate services.
  1. The plan addresses in a meaningful way the guidelines in this document and is consistent with the organization's mission.
  2. The plan has defined short-term and long-term goals and outcomes that incrementally improve services to LEP individuals, persons who are hard of hearing or deaf, and persons with low literacy.
  3. There is an Identifiable staff member responsible for overseeing its implementation.
  4. The plan is data driven, based on analysis of verifiable demographic and service data.
  5. The data includes the consumers' self-identified primary spoken language, race, and ethnicity.
  6. The plan assesses new and emerging community/population needs.
2.  Organizations should implement strategies to recruit, retain, and promote at all levels, diverse personnel and leadership that are representative of the demographic characteristics of the service area.
  1. Demonstrated hiring, retention and promotion of staff of racial/ethnic backgrounds representative of target population served.
  2. Personnel at different levels receive ongoing education and training in culturally and linguistically service delivery.
  3. Establish requirements for specific language skills in job descriptions and remuneration for language skills.
3. Organizations should collect customer data to ensure that every effort is made to provide consumers with effective, understandable, and respectful services, provided in the consumer's preferred language and in a manner sensitive to cultural beliefs and practices.
  1. The data assesses new and emerging community/population needs.
  2. The data includes the consumers' self-identified primary spoken language, race, and ethnicity.
  3. Organizations track consumer satisfaction with language access services and organizational sensitivity to consumer culture.
4.  Organizations shall provide hearing impaired and language assistance services, including bilingual personnel and interpreter services, at no cost to each consumer with limited English proficiency, or those who are hard of hearing or deaf, at key points of contact, in a timely manner that facilitates maximum access to services.
  1. Evidence that appropriate interpretation services are provided to the LEP, hard of hearing, or deaf consumers in a timely manner.
  2. Language fluency is assessed to determine the level of competence of personnel and interpreters to provide language and/or American Sign Language services in their specific field of service.
  3. Family, friends, or other untested individuals are not used to provide interpretation services.
5.  Organizations shall provide to consumers in their preferred language both verbal and written notices of their right to receive language assistance services that are culturally appropriate.
  1. Easily understood consumer-related materials and visible notices posted in languages of commonly encountered groups represented in the service area.
  2. Pertinent written, oral, and symbolic consumer materials (including consent forms, statement of rights forms, posters, signs, and audio tape recordings) are available in the language of the consumer and/or Braille and available at all key points of access.
  3. Quality assurance measures in place to verify accuracy of translated documents.

Section 1 

Linguistic and Cultural Competence Guidelines

This contract includes a goal of improving access to programs, services, and activities for LEP customers of the State of Illinois (Goal). Vendors are asked to demonstrate their capacity to serve LEP customers in accordance to the LCC guidelines. Vendors should include any additional information that will add clarity to the Vendor's proposed plan to provide access to services for LEP customers. Vendor should demonstrate it has strategies in place to assist LEP, hard of hearing, and/or deaf customers and persons with limited literacy, or has made good faith efforts to do so. The Vendor submission should address the following:

  1. Provide a general description of the linguistic and cultural competence plan for the funded program(s) or for the organization as a whole that includes clear goals, outcomes, policies and/or procedures related to the provision of culturally and linguistically appropriate services.
  2. Describe the strategies used to recruit, retain, and promote at all levels, diverse personnel and leadership that are representative of the demographic characteristics of the service area. Provide a list of personnel positions and staff details (name, contact information) at different levels and across relevant disciplines who receive ongoing education and training in culturally and linguistically appropriate service delivery.
  3. Describe the procedures that ensure that consumers receive effective, understandable, and respectful services, provided in the consumer's preferred language and in a manner sensitive to cultural beliefs and practices. Include description of data collection procedures.
  4. Describe any language assistance services, including bilingual personnel and interpreter services, cost of services, point of accessing the service, and how the service is delivered.
  5. Describe practices established to ensure consumers receive both verbal and written notices, in their preferred language, of their right to receive language assistance or American Sign Language services that are culturally appropriate. List any consumer-related materials and signage in languages of commonly encountered groups represented in the service area, including the languages in which the materials are available.

Section 2

Demonstration of Good Faith Efforts

Where Vendors cannot demonstrate they have the organizational capacity currently to meet the Goal of improving access to services, programs, and activities for LEP, hard of hearing or deaf customers, and persons with limited literacy, they must demonstrate good faith efforts as described below. In addition, the Good Faith Efforts checklist must be initialed by the representative who is certifying on behalf of the Vendor and submitted with the solicitation response (or as otherwise specified by the Agency. Failure to do so may result in a loss of points, putting the Vendor's solicitation response at risk of being non-competitive.

Good Faith Efforts Checklist

Insert on each line below the initials of the authorized Vendor representative who is certifying on behalf of the Vendor that the Vendor has completed/will complete the activities described below. If any other efforts were made to improve access to services, programs, and activities for LEP, hard of hearing or deaf customers, and persons with limited literacy, in addition to the items listed below, attach a detailed written explanation.

__ Solicited through all reasonable and available means, the services of a Vendor to provide interpretation and/or translation services, or other services (LCC Vendor) that will assist the Vendor in meeting the goals of the LCC Guidelines.

__ Used the services of available minority community organizations; minority vendors' groups; local, State, and federal minority business offices; and other organizations that provide assistance in meeting the Goal.

__ Established clear and achievable long-term goals and strategies for improving language and cultural competence. The long-term goals and strategies include measurable goals and outcomes, timelines for implementation, and other evidence of working towards meeting the Goal.