Are you in compliance with Title VI?
2nd seminar on Title VI draws even bigger crowd

Bruce Adelson of Federal Compliance Consulting and Jinny Bromberg of Bromberg & Associates, conducted another educational session on Title VI Compliance for Recipients of Federal Funds. It took place on 3/12 and attracted more attendees than ever before.

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.

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.

Seminar participants represented wide range of industries: health care, mental health, social services, education, human resources, public transportation, public housing, Wayne County Airport Authority, and hospitality industry. Each of these industries and organizations requires designing of the language plan access tailored to their specific needs. There is no “one size fits all” solution for providing meaningful language access. However, each participant was able to gain better understanding of a competent design of the Title VI Compliance plan.

In the post-seminar survey, the participants were asked to rate on the scale from 1 to 10 whether the seminar changed their outlook on utilization of language services and quality assurance of language services. The average rating turned out to be 9.4. Most participants came to appreciate that a trained interpreter is a highly qualified professional and that being a bilingual is not sufficient enough to serve as an interpreter. Jinny Bromberg shared the screening, training, and performance evaluation techniques developed and utilized by her agency.

Bromberg and Adelson are planning to conduct more educational sessions, both in Metro Detroit and in the western part of the state.