Title VI Compliance for Recipients of Federal Funds
Whether your organization receives money from federal sources directly or indirectly, you are still required to comply with Title VI

November 7, 2007

Bruce Adelson of Federal Compliance Consulting and Jinny Bromberg of Bromberg & Associates, conducted first educational session on Title VI Compliance for Recipients of Federal Funds.

Title VI of the Civil Rights Acts prohibits recipients of federal financial assistance from discrimination in their programs or activities based on race, color, or national origin. According to the United States Supreme Court, language-based discrimination equates with national origin discrimination. It means that if the organization receives federal money, grants, loans, subsidies or any type of U.S. government assistance, it is obligated to provide people who do not speak English well with “meaningful access” to its services. “Meaningful access” means that federal financial aid recipients must provide limited English proficient persons with assistance in their native languages, for example, by providing interpreters and translations of “vital” documents.

The first educational session and following discussion have been a success. Adelson and Bromberg provided participants with a multidimensional approach to the Title VI implementation.

Bruce Adelson, a former U.S. Department of Justice, Civil Rights Division Attorney, whose firm specializes in federal compliance consulting, illustrated legal consequences of failure to follow the law, including revocation of federal funding and severe penalties. He also offered his expertise on ways of successful implementation of the Title VI compliance plan and application of the Department of Justice’s four factor analysis to the provision of services for LEP individuals.

Jinny Bromberg, Michigan and Minnesota State Certified Court Interpreter and founder of Bromberg & Associates, in turn, brought up a viewpoint of a language professional on quality control for language services. She discussed the steps of a comprehensive language assistance plan and efficient solutions in providing language access.

Participants from Metro Detroit, Kalamazoo, and Holland represented two major industries, transportation and health care. One of the Department of Transportation attendees admitted that his view on the quality of language services has been changed dramatically. “Often we have volunteer interpreters, but now I see how risky that could be,” he said. Some of the healthcare providers shared their difficulties in persuading patients and the healthcare community that a medical interpreter is a highly qualified professional. Being a bilingual is not sufficient enough to serve as an interpreter.

Overall, all the participants agreed that the issue of language access in our state could not be swept under the carpet any longer. Provision of qualified interpreting and translation services is an essential part of providing services to LEP consumers and creating awareness as to the importance of these services is a first step. Bromberg and Adelson are planning to conduct more educational sessions, both in Metro Detroit and in the western part of the state.