4218 Procedure – Language Access Plan

The following procedures are intended to implement Policy 4218, establish meaningful, two-way communication between the district and parents/family members with limited English proficiency and promote access for such parents and families to the programs, services and activities of the district.

 

A. Definitions

    1. Persons with “limited English proficiency” are individuals who are unable to communicate effectively in English either verbally or in writing, or both, because their primary language is not English, and they have not developed fluency in the English language. A person with limited English proficiency may have difficulty in one or more of four domains of language: speaking, listening, reading, and writing. Staff are urged to remember that limited English proficiency may be context-specific—e.g., a parent may have sufficient English language skills to understand, communicate and/or exchange basic information with a teacher, but they may not have sufficient skills to communicate detailed, specific information needed in a particular context, like an IEP meeting, a 504 meeting, or a student discipline hearing.
    2. LEP parent(s)” refers to the parent(s) or guardian(s) of a student or students enrolled in the district who have limited English proficiency, even if the student is proficient in English. This term does not include family members of the student other than their parent(s) or guardian(s).
    3. “Primary language” means the primary language spoken by a student’s parent or guardian, or the predominant language spoken in the student’s home. Parents may have more than one primary language and/or dialect.
    4. “Language services” refers to a broad spectrum of services used or required to facilitate communication and understanding between speakers of different languages, and typically includes interpretation and translation services.
    5. “Interpretation” means the process of first fully understanding, analyzing, and processing a spoken or signed message and then faithfully rendering it into another spoken or signed language.
    6. “Interpreter” means a spoken language or sign language interpreter working in a public school, as defined in RCW 28A.150.010, to interpret for students’ families, students, and communities in educational settings. The district will take reasonable steps to utilize interpreters who have demonstrated language proficiency or who are employed by a particular vendor or service contracted to provide interpretation services.
    7. “Translation” means the written communication between a speaker of English and a speaker of another language where in the written words of one person are communicated to others in writing in a different language

B. Language Access Program

The district’s language access program will include completion of the following activities:

    • Adopting or developing a language access plan that outlines how the district will identify language access needs, allocate resources, establish standards for providing language access services, and monitor the effectiveness of the language access program.
    • Administering a self-assessment for evaluating the provision of language access services; which is part of the toolkit described in RCW 28A.183.030;
    • Developing, implementing, and evaluating the district’s language access policy, procedures, and plan, which is part of the toolkit described in RCW 28A.183.030. The processes for developing and evaluating the language access policy, procedures, and plan will engage staff, students, families and other community members in ways likely to result in timely and meaningful feedback; for example partnering with community-based organizations and providing translation and interpretation in languages that are understood by students’ families.
    • Reviewing, periodically, the district’s language access policy and procedures adopted as required under subsection (B) of this section to incorporate updates made to the model policy and procedures described in our RCW 28A.183.060;
    • Collaborating with community-based organizations on how to work effectively with interpreters and families; and
    • Reviewing, updating and publishing, at least annually, information about the school district’s language access plan, policy and procedures, and language access services, including the need for, spending on, language access services. The information must include notice to families about their right to free language access services and the contact information for any school district language access coordinator and any building points of contact for language access services. The information must be translated into common languages understood by students’ families.

 

 

Developing a Language Access Plan

The district will develop a language access plan for ensuring the district complies with the language access policy and all other language access requirements. The language access plan will establish the following:

    • Who is responsible for implementing the plan, including district-level administrators, or other district and school staff who will be responsible for overseeing the language access work in the district and schools, developing, and modifying the language access plan, establishing, and implementing operational procedures (i.e., how staff may access interpretation and translation services), and monitoring and evaluating the effectiveness of the district’s language access plan and services.
    • Staff training on the district’s language access policy, procedure, and plan.
    • Identification of the language access needs in the district and the services that will be provided.
    • What resources will be allocated for the provision of language access services.
    • The district will monitor and evaluate the effectiveness of the language access plan and services. The district will create a process for modifying the plan in response to feedback.
    • In developing and modifying the language access plan, the district will use self-assessment data and other collected feedback and data required in this procedure and/or the policy.
    • In developing the language access plan, the district will adhere to the standards for providing language access services as outlined in this procedure and policy.

 

Self-Assessment

In developing the language access plan, the language access coordinator/liaison will administer a self-assessment to understand whether the district is effectively communicating with people with language assistance needs and to inform the district’s language access planning, including evaluating the following areas:

    • How individuals with language access needs interact with the district.
    • How well the district is providing language assistance services.
    • How well the district is identifying individuals with language access needs.
    • Whether school staff receive appropriate training on the district’s language access and policy and plan.
    • How the district provides notice of language assistance services to its community.
    • Whether the district has an effective process for monitoring and updating its language access policy and plan.
    • In implementing the self-assessment, the language access coordinator will engage with community members, leaders, and organizations that have the inherent knowledge about cultural and language access needs.
    • The coordinator may administer the self-assessment tool developed by the OSPI Language Access Technical Assistance Program of Center for Improvement of Student Learning, established in RCW 28A.300.130 for evaluating the provision of language access services.
    • The coordinator/liaison will re-administer the self-assessment on a periodic basis as part of the district’s monitoring of the effectiveness of its language access program.

C. Identification of Families Needing Language Access Services

    1. Upon student enrollment and periodically through a student’s education, schools will utilize a survey to identify parents who need language access services and the languages in which they may need assistance. The survey will be translated into the most commonly known languages spoken in the district and will be included in the standard enrollment packet provided to all district parents.
    2. Schools must determine within thirty (30) days of a student’s enrollment the primary language spoken by the parent of each student enrolled in the school, and if such language is not English, whether the parent requires language services to communicate effectively with the school or district.
    3. Schools will maintain an appropriate and current record of students’ families’ primary language and use that information to inform its language access plan and program.

D. Interpretation and Translation Services

    1. The district will collaborate with community-based organizations on how to work effectively with interpreters and families.
    2. As materials become available, the district will make reasonable efforts to implement the toolkit developed by the Language Access Technical Assistance Program of the Center for the Improvement of Student Learning, established in RCW 28A.300.130, including the self-assessment, guide, and best practices.
    3. Each school and district office will take reasonable steps, consistent with this policy and procedure, to provide free oral interpretation services to parents/family members who require language services in order to communicate effectively during interactions with the district that are significant to the student’s education. Additionally, each school and district office will take reasonable steps to provide free translation of vital documents as required below.
    4. All interpretation and translation will be provided by competent interpreters and translators of that language. The district will take reasonable steps to ensure that interpreters and translators have the knowledge in both languages of any specialized terms or concepts to be used in the communication at issue, and that they have been trained in the role of an interpreter or translator, the ethics of interpreting and translating and the need to maintain confidentiality.
    5. The parent is welcome to invite additional persons for support and that person may participate in discussions. Although a parent may decline the district’s offer to provide an interpreter, the district or school should consider whether having an interpreter present as the communication lead is still required. Students and other minor children under the age of 18 may not serve as interpreters for school staff and parents during any formal or informal meeting or process.
    6. The district will take reasonable steps to facilitate staff access to appropriate interpretation and translation services in order to communicate with parents and families with limited English proficiency consistent with federal and/or state law and this policy and procedure. The district will strive to be aware of and plan for the language access needs within the district. For a planned program, activity, meeting, or event, staff should initiate the request for language aid or services at least five (5) or three days (3) ahead of time depending on the language (see clear guidelines below). The district or school will take steps to respond to such a request as soon as possible after it is received. For unplanned and urgent communication, staff should request language assistance and try to arrange for such as soon as it is known that language assistance is needed. If an interpreter cannot be found that day, the school or district should maintain open communication with the requester to schedule an interpreted meeting as soon as possible. If no interpreter can be present, district staff should utilize remote interpreting services to communicate with parents and families.
    7. District staff can view on the Staff Hub when and how to access interpretation and translation services available within the district and the administrator responsible for ensuring the availability of such services.

Interpretation & translation services are currently available, please contact:

a. STAFF:

For questions or concerns, or to obtain information or assistance regarding interpretation and translation services. Staff may contact Isabel Meaker at isabel.meaker@bellinghamschools.org or 360-676-6456 with questions or concerns, or to obtain information or assistance regarding interpretation and translation services.

b. FAMILIES:

i. Call or email your Family liaison.

ii. Connect directly with Interpretation & Translations services office 360-676-6456 x4853 / Mobile: 360-746-9132.

iii. Leave a voicemail on our Multi-Language message line (for parents only) @ 360-647-6816.

iv. Connect with FRC @ 360-676-6456 / frc@bellinghamschools.org

    1. District administrators, including those involved with registration and enrollment, certificated staff and other appropriate staff as determined by the superintendent, will receive guidance and information regarding:

a. The rights of parents and families with limited English proficiency under state and federal law to language services provided by the district;

b. the importance of meaningfully and effectively communicating with LEP parents and families with limited English proficiency;

c. the most effective ways to communicate with parents and families with limited English proficiency regarding the district’s available language services;

d. the importance of utilizing competent translation and interpretation services when communicating with LEP parents and families with limited English proficiency;

e. the availability of translation and interpretation services within the district, whether through in-person interpretation, telephonic services, online services, or video-conferencing;

f. the mechanisms and processes for accessing translation and interpretation services when working with LEP parents and families with limited English proficiency, including ensuring the correct language service is being accessed, checking for parent/family understanding once interpretation has commenced, and proper vetting of translations for audience-appropriate content; and

g. the process for reporting concerns or complaints.

9. Interpretation Services

Whenever requested by a parent or families or whenever school staff or district officials can reasonably anticipate that interpretation services are necessary to meaningfully communicate with parents or families regarding important information about their student’s education or school activities, the district will take reasonable steps to provide interpretation services in accordance with this procedure.

Such interpretation services may be provided either at the location where the parent or family member is seeking to communicate or by electronic means, such as telephone or video conferencing.

Upon three (3) school business days’ notice that such services are required, the district will take all reasonable steps to provide interpretation services for the top four (4) languages spoken in addition to English at public meetings organized or sponsored by the District (e.g., School Board meetings).

Upon five (5) school business days’ notice that such services for any other languages (included sign language) are required, the district will take all reasonable steps to provide interpretation.

10. Translation of Vital District Documents

The district will identify vital documents that are distributed or electronically communicated to all or substantially all parents containing important information regarding a student’s education, as stated in Policy 4218.

a. school registration.

b. academic standards and student performance;

c. safety, discipline, and conduct expectations;

d. special education and related services, Section 504 information, and McKinney-Vento services;

e. policies and procedures related to school attendance;

f. requests for parent permission in activities or programs;

g. opportunities for students or families to access school activities, programs, and services;

h. student/parent handbook;

i. the district’s Language Access Plan and related services or resources available;

j. nondiscrimination notices;

k. parent-teacher conferences;

l. Highly Capable Learners services;

m. school closure information; and

n. school closure information; and

o. any other documents notifying parents of their rights under applicable state laws and/or containing information or forms related to consent or filing complaints under federal law, state law, or district policy.

The district will provide a written translation or oral interpretation of vital documents for each language group that constitutes at least 5 percent of the district’s total parent population or 1000 persons, whichever is less. If the district is unable to translate a document due to resource limitations or if a small number of parents require the information in a language other than English such that document translation is unreasonable, the district will still provide the information to parents in a language they can understand, such as through oral interpretation of the document.

Written translations of vital documents by machine/computer translation programs will not be used or issued to LEP parents without prior review by a district-approved translator.

Written translations of vital documents by machine/computer translation programs will not be used or issued to parents and families with limited English proficiency without prior review and editing by a district-approved translator.
All documents and information posted or issued by the district for parents and families should contain a notice in appropriate language(s) that free translation and/or interpretation services are available and how to request a free translation or interpretation of the document.

11. Translation of Student-Specific Documents

The district will take all reasonable steps to provide parents and families, in a language they can understand, a translation or oral interpretation of any document that contains individual, student-specific information regarding, but not limited to, a student’s:

a. health;

b. safety;

c. legal or disciplinary matters; and

d. entitlement to public education, eligibility for special education services, placement in the Multilingual Language Learner Program (MLL), the Highly Capable Program, accelerated courses such as Advanced Placement, or any other non-standard academic program.

12. Alternatives to Translation

When translation for a document otherwise required to be translated is unavailable or cannot be done, such as in an emergency situation, a school or district office will provide an attached notice to parents and families in appropriate language(s) that free translation and/or interpretation services are available and how to request a free translation or interpretation of the document.

Example: English

This is an important document about your child’s education. If you need this information in another language, please contact your school district at [360-676-6456] to have this translated for you at no cost.

E. Providing Information to Parents and Families

    1. The district will periodically review, update and publish information about the school district’s language access plan, policy and procedures, and language access services.
    2. The district will periodically inform staff of this policy. Staff will be regularly provided with guidance regarding how and when interpretation and translation services should be accessed and such guidance will be updated as needed to reflect available services.
    3. Parents and families will also be annually notified regarding the process for filing complaints through the district’s nondiscrimination policy and procedure if they believe that such services have not been appropriately provided.
    4. The district will take reasonable steps to provide information required by this section in the primary language spoken predominantly in the home. The district will take steps to ensure that, at the time of enrollment, information regarding available interpretation and translation services and the district’s complaint process is provided to any parent (s) or family members when there is reason to believe that the student’s parent(s) or family members may have limited English proficiency (e.g., results of home language survey, a parent or family member’s request for an interpreter). The district will take reasonable steps to provide information required by this section in the primary language spoken predominantly in the home.
    5. Schools and district offices will post in a conspicuous location at or near the primary entrance to the school or office a sign in primary languages spoken in the district concerning the rights of parents to translation and interpretation services and how to access such services.
    6. To the extent practicable, the district website will provide information in designated languages concerning the rights of parents to translation and interpretation services under federal and state law and how to access such services.

F. The Collection and Analysis of LEP Data

The district will annually collect and analyze data related to limited English proficiency parents/families to assemble a list of primary languages spoken predominantly in the homes of students and their parents. Such information will help to ensure the provision of appropriate language access services and assist the district in effectively planning and budgeting for services necessary to communicate with students and their parents.

Such data may be collected by parent surveys.

The district will provide an opportunity for participants in interpreted meetings to provide feedback on the effectiveness of the interpretation and the provision of language access services.

Discrimination Complaints

Discrimination based on national origin, which includes language and limited-English proficiency, is prohibited. The language access liaison/coordinator will communicate with the district’s Civil Rights Compliance Coordinator. Anyone may file a complaint alleging discrimination based on language or the district’s failure to provide language access services using the complaint process outlined in the district’s Nondiscrimination Procedure 3210P.

Adopted/Previous Revisions: 07/26/18
Updated: 09/12/24