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Summary of Voluntary Compliance Agreement

On August 11, 2000, President Bill Clinton signed Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency,” requiring federally-assisted programs, such as housing authorities, to draft and implement language access plans that would assure that individuals with Limited English Proficiency (LEP) would have meaningful access to their programs.  On January 22, 2007, HUD released its Final LEP Guidance, setting forth its expectations of what steps would be required to be in compliance with 13166.

In response to this, in the summer of 2009, the Columbus Metropolitan Housing Authority drafted a Language Access Plan, promising to translate all vital documents into Spanish and Somali. The Plan promised voicemail options in Spanish and Somali, and called for the Plan to be published on its website.  These steps were to be completed by October, 2009. 

By 2014, CMHA’s Language Access Plan had been removed from the CMHA website, voicemail options were only in English, and vital documents were never being translated. In April, 2014 LASC and leaders from the Somali Community Association of Ohio met with CMHA and requested the 2009 plan be implemented.  CMHA promised more meetings but remained non-committal.  In June, 2014, LASC contacted the Columbus Dispatch which ran a front-page article, “Lost in Translation,” describing the problem. Finally, in July 2014, LASC filed an Administrative Complaint with HUD, alleging that CMHA’s failure to implement its Language Access Plan of 2009 was a violation of Title VI of the Civil Rights Act of 1964 which prohibits discrimination on the basis of national origin in programs and activities receiving federal financial assistance.

On March 3, 2015, HUD’s office of Fair Housing and Equal Opportunity advised CMHA in a letter that it was opening an investigation based on the Complaint, and would be undertaking a Title VI compliance review.  Before the commencement of this process, CMHA requested a meeting with HUD and LASC, at which it advised that it would prefer to resolve the matter through a Voluntary Compliance Agreement (VCA).  On September 30, 2015, after several meetings between LASC, HUD, and CMHA, the parties reached an agreement resolving the Administrative Complaint.  Pursuant to that agreement, CMHA is required to draft and implement a new Language Access Plan that contains numerous specific provisions designed to provide meaningful access to its LEP clients, including:

  • translating an expanded list of vital documents into Spanish and Somali at least, and possibly some other languages;
  • updating Spanish and Somali language voice responsive systems for its telephones;
  • creating systems for CMHA employees to access interpreters;
  • giving all its staff serving clients “I speak” cards;
  • training staff on language access;
  • posting fair housing posters in Spanish and Somali.

In addition, HUD has agreed to monitor CMHA’s implementation of the Language Access Plan through September, 2018.

 

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