For Persons With Limited English Proficiency

SOCIAL SECURITY ADMINISTRATION'S PLAN FOR PROVIDING ACCESS TO BENEFITS AND SERVICES FOR PERSONS WITH LIMITED ENGLISH PROFICIENCY (LEP)

Content

Summary

Social Security's LEP Service Vision and Policy Elements

Social Security's Four Factor Analysis

Section I: Number or Proportion of LEP Individuals

Section II: Frequency of Contact with Program

Section III: Nature and Importance of the Program

Section IV: Resources

Plan Accomplishments

Name of Project: Social Security Administration's (Social Security's) Plan for Providing Access to Benefits and Services for Persons with Limited English Proficiency (LEP)

Introduction: Section 2 of Executive Order 13166 requires Federal agencies to develop and implement a plan for improving access to services and participation in federally conducted programs and activities to LEP individuals. The Department of Justice (DOJ) requested that each agency submit its plan to improve the language accessibility of its federally conducted programs and activities and to take steps to implement the plan. Social Security submitted its original LEP plan to DOJ on December 19, 2000.

According to DOJ, each agency and each recipient of Federal financial assistance must take reasonable steps to provide meaningful access to LEP individuals using a "4-factor" analysis. The factors to be considered in determining what constitutes reasonable steps to ensure meaningful access are the:

• number or proportion of LEP persons in the eligible service population;

• frequency with which LEP individuals come into contact with the program;

• importance of the service provided by the program; and

• resources available to the recipient.

Background: Social Security's efforts to improve services to increasing numbers of LEP individuals predate Executive Order 13166, issued in August 2000. In February 1995, Social Security chartered the LEP inter-component workgroup, which meets monthly and is responsible for all Agency activities, including monitoring and oversight to improve services to LEP individuals. In September 1995, Social Security's LEP policy, principles and implementation plan were approved by the Commissioner. Since then, Social Security has taken a proactive approach to implementing a comprehensive plan to provide access to program benefits and services to LEP individuals.

Social Security’s LEP plan:

• Supports Executive Order 13166 by providing meaningful access to our programs, benefits, services and information for LEP individuals using the four factor analysis recommended by DOJ;

• Provides clear, consistent direction in the delivery of efficient, effective and caring service to LEP individuals;

• Articulates an Agency approach to the LEP service issue;

• Balances service needs of LEP individuals with the fiscal constraints of Social Security operations;

• Provides a framework for resource allocation decisions in the context of all Agency business; and

• Supports current activities while including long-term service initiatives.

Contact Person: Ed Beane, 410-965-9866, ed.beane@ssa.gov

Vision Statement: Social Security provides effective, efficient and equitable service to the public we serve. Members of the public have access to our services regardless of their ability to speak, read or write English. Service delivery options are available to LEP individuals, enabling them to communicate effectively with Social Security in person, over the phone, in writing or through electronic media.

Policy: We have taken a proactive approach to ensure access to the programs we administer to all of the American public by clarifying and distributing our LEP policy and procedures to make public contact employees and the public aware of our service delivery guidelines.
Our policy ensures that individuals have access to our programs and services regardless of their ability to communicate with us in English.

Our LEP policy principles, approved in 1995, include the following elements:

Resource Allocation - We will consider the needs of LEP individuals in all of our Agency policies and long-range business and strategic plans. Service needs of LEP individuals are factored into the allocation of Social Security resources and we adopt service delivery initiatives that we can fully fund.

Service Delivery - LEP individuals have access to Social Security's services through its network of over 1,300 field offices and the national 800 telephone number. Field offices are allowed to develop strategies tailored to the needs of their community to provide efficient and effective service.

Bilingual Staffing - The most effective method for providing quality service to LEP individuals is through bilingual public contact employees. Our standard for field office staffing is to achieve at least proportional representation for each language group constituting a significant portion (i.e., 10 percent) of the workloads generated in an office's service area.

Qualified Interpreter Services - Social Security will provide an interpreter, at no cost to the LEP individual, if s/he requests language assistance, or it is evident that such assistance is needed. Social Security uses either qualified office interpreters or interpreters available through a national contract to provide telephone interpreters.

If an LEP individual prefers to provide his/her own interpreter, Social Security will use this interpreter if s/he can provide meaningful access for the individual, is acting in the claimant's best interest and there is no indication of fraudulent activity. Social Security will not use a minor child as an interpreter if another interpreter can be obtained, though the minor can participate in the interview along with the authorized interpreter at the LEP individual's request.

Public Information - Social Security recognizes the value of public information to educate, improve access to our services, address LEP concerns, promote program integrity and build public confidence in the programs we administer. Social Security produces public information materials in languages other than English and uses national and local media to provide this information to LEP individuals.

Written Communications - In order to facilitate access to its programs and to improve administrative effectiveness, Social Security nationally produces written communications such as public information materials, notices and form letters, using the following criteria:

• number of LEP beneficiaries/applicants;

• number of impacted field offices;

• literacy level in the non-English language;

• anticipated demographic growth; and

• cost-effectiveness--national vs. local

(See accomplishments for list of material in languages beyond English)

Social Security is working toward providing all automated notices in Spanish. As a long-term goal,

Social Security plans to produce automated notices in languages other than English and Spanish.

Listening to LEP Individuals - Social Security has mechanisms (focus group testing and the Agency comment and suggestion system) in place to respond to the publics' concerns and comments and continues to assess the quality of service provided to our LEP applicants, recipients and beneficiaries.

Better communication with LEP individuals:

• increases client satisfaction when we provide service by bilingual/bicultural staff;

• improves program integrity by eliminating fraud perpetrated by middlemen;

• increases public understanding of our programs by providing information to clients in a language they read, speak and understand; and

• streamlines contacts by identifying the language preference at the initial contact, so there is no need for re-contacts.

Technology - When evaluating existing and new or emerging technologies, we consider the needs of LEP individuals.

Training - Social Security provides training opportunities in cultural diversity for all employees, especially our public contact employees, so they can better serve LEP individuals. Social Security provides training to upgrade language skills for its bilingual employees for all major languages requested.

Monitoring Our Services - Social Security identifies and tracks LEP workload data on an ongoing basis at the national, regional and local levels to determine what the needs are and to allocate resources accordingly. Social Security monitors our LEP policies and practices to ensure that they continue to be effective. Social Security periodically reevaluates the language groups most represented among LEP individuals to determine shifts in the non-English speaking demands.

Social Security is committed to providing LEP individuals the same access to services that is provided to members of the public who speak English. Social Security recognizes the diversity of the public and the need to be sensitive to their special needs. LEP individuals generally need more personal service (e.g., interpreter services for face-to-face or telephone interviews and assistance in translating documents) across program lines.

Section I. Demography: Number or Proportion of LEP Individuals:
Has your organization developed a demographic profile of the population served?
Yes. We began collecting and projecting the language preference for 26 languages as early as 1996. Using these projections, in fiscal year (FY) 2001, approximately 9 percent or 2,144,380 claimants preferred to be interviewed in a language other than English. Over 74 percent of our foreign language demand was for Spanish, Chinese (Cantonese and Mandarin dialects) was 4 percent, and Russian was 2 percent.

Capturing language preference through our automated claims process ensures that we:

• know the preferred languages of the public;

• know where these demands are located; and

• are able to make more informed staffing and resource allocation decisions.

The following is an array of the top five language preferences by workload category for FY 2001:

(NOTE: The "Other" category represents languages not listed in the following chart for "SSI Recipient language preference collected since 1996"

The highest percentage of foreign language demand is in SSI Aged applications. In FY 2001, almost 35 percent of those applicants preferred that their interview be conducted in a language other than English. This represented over 50,000 applicants nationwide.

The following represents SSI recipient language preference collected since 1996:

Future systems enhancements include expanding the number of language preferences for which we collect preference data. Having the ability to collect additional language preference data on the populations we serve will allow us to fill gaps in service by increasing bilingual staff and making them available in places where their bilingual skills can be used. In addition, we plan to develop a strategy to identify the language preference for SSI beneficiaries who became eligible for SSI before we began collecting language preference.

Section II. Frequency of Contact with the Program: Does your organization collect/record primary language data for individuals who participate on your programs?
Yes. LEP individuals come into contact with Social Security on a daily basis: in person, by mail, by phone or by Internet, to apply for benefits, request services or ask questions about the programs we administer. The following represents the overall volume of specific workloads we processed in FY 2001:

As noted above in Section I, we collect written and spoken language preference for individuals who apply for:

• Retirement, Survivors and Disability Insurance;

• Supplemental Security Income; and

• Social Security Numbers.

Section III. Nature and Importance of the Program. In 1937, the Social Security Act established a program to help protect aged Americans against the loss of income due to retirement. Protection for survivors of deceased workers was added in 1939, creating the Old Age and Survivors Insurance (OASI) program. Social Security was again expanded in 1956 to include the Disability Insurance (DI) program. Social Security’s responsibilities also include administration of the Supplemental Security Income (SSI) program added in 1972, and Special Benefits for Certain World War II Veterans (title VIII) added in 1999. Social Security provides social insurance protection for more than 142 million workers and their families. For the fiscal year ending September 30, 2001:

• 38.9 million Americans were receiving OASI benefits totaling $367.7 billion;

• 6.8 million Americans were receiving DI benefits totaling $58.2 billion; and

• 6.7 million people were receiving SSI benefits totaling $27.4 billion.

Though Social Security administers the programs listed above, we highlight the SSI program due to its high volume of language demand. See the chart in Section I, which lists the top five language preferences by workload category for FY 2001. Through this program, we pay monthly benefits to people with limited income and resources who are age 65 or older, blind or disabled. Blind or disabled children, as well as adults, can receive SSI. In most States, filing for and receiving SSI results in eligibility for Medicaid (medical assistance) to pay for hospital stays, doctor bills, prescription drugs and other health costs. Also, in most States, Food Stamp information and an application are provided to individuals applying for or receiving SSI.

Thus, for LEP individuals, who are either age 65 or older, blind or disabled, Social Security plays a critical role in helping provide monthly benefit payments and linkages to medical and nutrition services.

Section IV. Resources. We have centralized management of the Social Security and Supplemental Security Income programs, the Office of Central Operations, and a decentralized nationwide network of 10 Regional Offices overseeing 1,340 Field Offices, 36 Teleservice Centers, 6 Program Service Centers. In addition, we have 138 Hearings Offices and 10 Offices of Hearings and Appeals (OHA) Regional Offices overseen by OHA headquarters.

As of May 2001, we have approximately 65,000 employees at Social Security. Of these employees, over 80 percent are involved in providing direct public service – they work in our field offices, teleservice centers, processing centers and hearing offices. As an Agency, Social Security is uniquely positioned through its network of public contact offices to provide assistance to LEP populations.

We direct resources to LEP activities in the form of:

• hiring bilingual staff (1,054 out of 2,908 in FY 2001) where bilingual skills are needed;

• providing for paid third-party interpreters ($832,871 for our field offices and $2,389,423 for our hearing offices in FY 2002) and a new contract for telephone interpretations;

• providing for contract translations and typesetting services ($100,000 in FY 2001) to produce foreign language public information material and training public contact employees ($300,000 allocated in FY 2001).

We increased the number of direct service employees who can speak a language in addition to English. Social Security’s hiring initiatives have focused on achieving the right mix of employee language skills to serve LEP individuals. Through December 2000 we identified 6,591 Social Security bilingual employees who speak 87 different languages. Since 1993, 34 percent (5,290 out of 15,264) of all new hires (public contact employees, representing field office and teleservice centers) were bilingual. When bilingual employees are not available, we pay for third-party interpreters. The following represents actual expenditures for interpreter services for FO's and OHA:

In addition, we contracted with Tele-Interpreters, a private telephone language interpreter service company, to handle immediate telephone language interpretations for Social Security public contact employees. This service becameavailable for use by all Operations and Hearing Office public contact employees effective October 7, 2002.

• Hired 5,290 bilingual public contact employees since 1993;

• Provided for third-party interpreter services at a cost of $832,871 to our field offices and $2,389,423 million for our hearing and appeals offices in FY 2002;

• Implemented a National Telephone Interpreter Service in October 2002. Social Security contracted with Tele-Interpreters, a private language service company, which handles telephone interpretations for Social Security public contact employees. The service is available 24 hours a day, 7 days a week;

• Completed a national roll-out of the Spanish language prompt to our toll free number in April 2001;

• Provided written materials in languages other than English. Many public information materials are available in additional languages on our web site at: http://www.socialsecurity.gov/multilanguage/. Public information materials we’ve completed in other languages include the following:

• Sample Social Security Statement translated into: Chinese, Korean, Spanish, Polish, Italian, Tagalog and Vietnamese.

• Retirement and Survivors Benefit fact-sheet translated into: Arabic, Armenian, Chinese, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese.

• Disability Benefits fact-sheet: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog and Vietnamese.

• Supplemental Security Income Rights and Responsibilities Handout: Arabic, Armenian, Chinese, Farsi, Greek, Haitian-Creole, French, Italian, Portuguese, Polish, Korean, Spanish, Tagalog, Russian, and Vietnamese.

• Special Benefits for WWII Veterans fact-sheet: Tagalog

• Representative Payee Dedicated Accounts fact-sheet: Armenian, Chinese, Hmong, Korean, Laotian, Tagalog, Russian and Vietnamese.

• A "Snapshot" of Social Security Programs translated into: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog and Vietnamese.

• Social Security Terminology Glossary English-Spanish; English-Haitian Creole; English-Korean; English-Chinese and English-Vietnamese;

• Translated 58 publications into Spanish, including Monthly Information Packages and Understanding Supplemental Security Income publication.

• Maintained En Espanol web site, which contains over 100 Spanish public information materials;

• Updated language skills of bilingual employees. Through December 2000, we identified 6,591 bilingual employees who speak 87 languages. Since this initiative began in FY 1997, over half of Social Security’s bilingual employees received training in medical and social welfare terminology;

• Developed Interviewing Guides and training in Spanish, Vietnamese, Navaho, Polish, Chinese, Russian, Filipino languages, German, French, Haitian-Creole, Italian, Korean and Portuguese; and

• Translated, distributed and displayed "interpreter service policy" posters in our field offices. The poster is translated into 19 languages.