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PART III: IMPROVING ACCESS TO SERVICES FOR PERSONS WITH LIMITED ENGLISH PROFICIENCY (LEP) 2-IILA. OVERVIEW Language for Limited English Proficiency Persons (LEP) can be a barrier to accessing important benefits or services, understanding and exercising important rights, complying with applicable responsibilities, or understanding other information provided by the HCV program. In certain circumstances, failure to ensure that LEP persons can effectively participate in or benefit from federally-assisted programs and activities may violate the prohibition under Title VI against discrimination on the basis of national origin. This part incorporates the Final Guidance to Federal Assistance Recipients Regarding Title VI Prohibition against National Origin Discrimination Affecting Limited English Proficient Persons, published January 22, 2007, in the Federal Register. SAHA will take affirmative steps to communicate with people who need services or information in a language other than English. These persons will be referred to as Persons with Limited English Proficiency (LEP). LEP is defined as persons who do not speak English as their primary language and who have a limited ability to read, write, speak or understand English. For the purposes of this administrative plan, LEP persons are HCV applicants and participants, and parents and family members of applicants and participants. In order to determine the level of access needed by LEP persons, SAHA will balance the following four factors: (1) the number or proportion of LEP persons eligible to be served or likely to be encountered by the Housing Choice Voucher program; (2) the frequency with which LEP persons come into contact with the program; (3) the nature and importance of the program, activity, or service provided by the program to people's lives; and (4) the resources available to SAHA and costs. Balancing these four factors will ensure meaningful access by LEP persons to critical services while not imposing undue burdens on SAHA. 2-III.B. ORAL INTERPRETATION In a courtroom, a hearing, or situations in which health, safety, or access to important benefits and services are at stake, SAHA will generally offer, or ensure that the family is offered through other sources, interpretation free of charge to the LEP person. SAHA will analyze the various kinds of contacts it has with the public, to assess language needs and decide what reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed substantially exceed the benefits. SAHA has bilingual staff to assist non-English speaking families in Spanish and Vietnamese and translates some documents into Spanish and Vietnamese. A local organization is used on an `as needed' basis to assist with Cambodian translations (both oral and written). Where LEP persons desire, they will be permitted to use, at their own expense, an interpreter of their own choosing, in place of or as a supplement to the free language services offered by SAHA. The interpreter may be a family member or friend. iii29i2oio Page 2-9