01.D.14 – Title VI Non-Discrimination Compliance and Limited English Proficiency Policy
Section: General Administration
Area: Legal Affairs
1. PURPOSE
The University of Houston System and its universities, as recipients of federal funds, are obligated under Title VI of the Civil Rights Act of 1964 to take reasonable steps to provide individuals with limited English proficiency meaningful access to each university's operations, services, activities, and programs. This policy describes how System universities may incorporate language access considerations in their routine planning, translate documents and provide interpretive services where appropriate, educate personnel about language access responsibilities, and inform faculty, staff, students, and visitors on how to utilize available language access resources.
2. DEFINITIONS
2.1. English Language Learner (ELL) – A national-origin-minority student who is limited-English-proficient. This term is often preferred over limited-English-proficient (LEP) as it highlights accomplishments rather than deficits. ELLs are also sometimes identified as Multilingual Students.
2.2. Limited English Proficiency (LEP) – Persons with Limited English Proficiency are defined as "those individuals who have a limited ability to read, write, speak or understand English." See English Language Learner (ELL).
3. SCOPE
3.1. Providing meaningful access to University services is a shared obligation of all employees. The Title VI Coordinator at each University provides education and instruction to offices/departments/programs on campus regarding how to assist LEP persons. Key topics include:
• Understanding Title VI LEP responsibilities;
• Creating awareness of language assistance services the university offers;
• Specific instructions on how to assist LEP persons; and
• Other Title VI obligations.
4. POLICY
4.1. Types and Means of Access to LEP individuals
4.1.1. Office and campus staff will promptly identify the language and communication needs of any LEP person who makes themselves known to the institution. Subject to any University requirements of language proficiency for employment or student admissions listed on applicable pages of the university's website, meaningful access to LEP persons must be accomplished by taking proactive steps, including: (i) providing the necessary language assistance services; (ii) training staff on policies and procedures; and (iii) providing notice of language assistance services and points of contact for additional information.
4.1.2. Each university may consider utilizing the following language access options depending on the situation:
A. Determining the language being spoken through descriptions, maps, or using language identification cards (such as "I speak cards") or posters
B. Providing Professional or Other Language Assistance Services
1. Professional Interpretation and Translation Services
Each university may use professional interpreter services, if available and economically feasible, to provide meaningful access to LEP persons to university programs and activities as applicable. Professional interpretation and translation services is recommended to translate official documents to ensure accuracy of translations.
2. Personnel with Foreign Language Skills
A number of staff members have foreign language skills. This includes native speakers as well as those who have acquired language skills through education and professional experiences. Personnel with foreign language skills may be able to effectively assist LEP persons in ordinary and less formal circumstances. However, because they may not have received formal training in interpretation or translation or may not necessarily be proficient in the foreign language, a university or department seeking to utilize personnel with foreign language skills should exercise caution before utilizing them for vital or official interactions, such as complaint forms or other situations involving complicated matters. Before relying on any of these staff members for communicating with LEP persons, personnel should consult with their supervisors and a LEP coordinator, as applicable, on whether it is appropriate for the staff member to provide the needed language services in a given situation. University departments are responsible for ensuring translation services are provided by qualified individuals.
3. Friends or Family of LEP Persons
LEP persons may elect to have friends or family assist them. If official matters are involved, the department should explain to LEP persons that the matters may involve complicated information and determine if the LED person is comfortable proceeding. A university cannot require an LEP person to bring their own interpreter.
4.2. Students
4.2.1. Each University shall state on its website the requirements for English language proficiency for admission of new students.
4.2.2. Each University will provide resources, support services and/or programs to foster success for all students through a writing center that shall, at a minimum, provide online resources, feedback on written compositions, and peer tutoring. ELL students shall have equal access to such resources, support services and/or programs as traditional students.
4.2.3. Training for staff working in writing centers at each University shall include instruction on working with ELL students.
4.2.4. Information regarding available academic support services and programs for students will be made accessible annually through the Student Handbook of each component university.
4.3. LEP Complaints
4.3.1. Individuals who believe they have not been provided reasonable access to LEP services may file a complaint with the appropriate Title VI Coordinator within 180 days after the last incident of denial.
4.3.2. The Title VI Coordinator may provide assistance to the LEP complainant through the means noted in Section 4.1.3 above or permit the LEP complainant to have an individual of their choosing to accompany them to provide interpreter services or to assist in filing. In this manner, the LEP complainant is ensured meaningful access to the complaint process.
4.4. Assessment
Title VI Coordinators will monitor the efficacy of these procedures to determine whether additional resources may be necessary.
REFERENCES
Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq.
Executive Order 13166 "Improving Access to Services for Persons With Limited English Proficiency''
Issued: 12/14/2018
Last Reviewed/Revised: 01/01/2022
Responsible Office(s): Academic Affairs; Student Affairs