Justice, Care and Opportunities Department (JCOD) Department Language Access Plan

Department Contact and Language Access Liaison: Brenda Duran, Director of External Affairs: pio@jcod.lacounty.gov

June 30, 2025

SECTION 1: OVERVIEW & CONTEXT

A. Department Mission

We cultivate a person-centered, coordinated continuum of care for vulnerable justice impacted individuals and their communities. By leading collaborative system improvement efforts, we focus on prevention, diversion and reentry to achieve community safety, wellbeing, and equitable justice. Language access is connected to our mission in that for justice-impacted clients to receive needed services, from prevention to reentry, in areas such as behavioral health support, supportive housing, social services, and workforce development, information needs to be presented in a language that they are proficient in and comfortable with. This will ensure that clients successfully access and navigate these services at every step of the way.

B. Department Priority Languages

English is the preferred language for 98% of JCOD’s client population, with Spanish being the next preferred language, as reflected in the department’s care management system. JCOD identified the following priority languages based on LA County’s designation of threshold languages (i.e., primary languages in the county), in addition to American Sign Language.

1. American Sign Language (ASL)
2. Arabic
3. Armenian
4. Chinese (Oral: Mandarin & Cantonese; Written: Simplified and Traditional)
5. English
6. Farsi
7. Hindi
8. Japanese
9. Khmer/Cambodian
10. Korean
11. Russian
12. Spanish
13. Tagalog
14. Thai
15. Vietnamese

JCOD currently utilizes two contractual agreements to support translation service needs in the department, which provides interpretation services via telephone by a professional qualified human interpreter in Arabic, Armenian, Mandarin, Cantonese, Farsi, Hindi, Japanese, Khmer/Cambodian, Korean, Russian, Spanish, Tagalog, Thai, Vietnamese and all other languages, and through video remote interpreting for ASL.

Los Angeles County Threshold Languages

SECTION 2: DEPARTMENT’S LANGUAGE ACCESS POLICY

C. General Policy Statement

JCOD is committed to providing equitable access to all services, programs, and information for individuals with Limited English Proficiency (LEP) and those who speak a Language Other Than English (LOTE). This commitment is rooted in our belief that language barriers should never impede access to justice, care, and opportunities. To uphold this commitment, JCOD offers free language assistance, such as interpretation and translation in priority languages. These services ensure that all individuals, regardless of the language they speak, can fully access the support and resources they need.

D. Scope of Policy

This policy applies to everyone who interacts with the public on behalf of JCOD, including:

• All JCOD employees (full-time, part-time, temporary);
• Contractors, consultants, and service providers funded by or working under agreement with JCOD;
• Volunteers, interns, and any other representatives of JCOD delivering public services or engaging with clients.

These individuals and organizations are responsible for making sure that LEP and LOTE individuals receive timely and accurate language assistance. This includes recognizing when help is needed and being aware about how to access interpretation or translation services.

SECTION 3: KEY TERMS & DEFINITIONS

1. JCOD: Justice, Care and Opportunities Department
2. LOTE (Language Other Than English): Refers to any language that is not English. This term emphasizes linguistic diversity and is often used in programmatic and community contexts to describe individuals or populations who read, write and speak a primary language other than English.
3. LEP (Limited English Proficient): Refers to individuals who do not speak English as their primary language but may self-identify to have a limited ability to read, write, speak, or understand English.
4. External Providers: Organizations or individuals contracted by JCOD to deliver services, programs, or interventions to clients. These providers must adhere to JCOD’s language access standards and are expected to support equitable access for LEP and LOTE populations.

SECTION 4: PROCEDURES

E. Identifying Preferred Languages

JCOD has identified that the majority of its clients speak English and Spanish, but interpretation services and service materials will be available in priority languages identified by the department. The department utilizes two vendor telephone interpretive in-person and over the phone interactions. Additionally, JCOD has proficient staff in languages other than English who can assist JCOD’s client population. When a language other than English is requested, JCOD employees will follow the procedure outlined here:

1. Identifying Language Needs: JCOD employees will ask the client if they prefer to communicate in a language other than English.
2. Language Identification Tools: If LEP or LOTE client is identified, JCOD employees will contact an interpretive service vendor by phone to connect with a qualified Language Specialist or IVR system to assist in identifying the spoken language.
3. Interpreter Access: Once the language is identified by the Language Specialist or IVR, JCOD employees and the client will be connected to a qualified interpreter.
4. Documentation of the Preferred Language: The client’s preferred language is documented in the client’s profile in JCOD’s care management system. The preferred language is visible to all care management system staff users to ensure ongoing support is provided in the client’s preferred language.

The table outlines key points of contact where JCOD engages with clients along with corresponding strategies implemented at each stage. Based on JCOD’s client population and preferred languages of English and Spanish, service documents are available in English and Spanish. Additionally, service documents will be developed and made available in other priority languages. All service materials will be developed using plain language at a 7th to 8th grade reading level to ensure accessibility and understanding.

Additionally, JCOD will:

• Create procedures and training to identify LEP and LOTE speakers upon their arrival with a JCOD contracted provider.
• Work to develop training so that staff and contracted providers are proficient in providing culturally competent services.
• Ensure compliance with federal, state, and local language access requirements.
• Equip staff with practical skills to interact effectively with LEP and LOTE individuals.

F. Vital documents

The following is a list of vital documents required for a LOTE speaker to be enrolled in a JCOD program and provided services. All listed documents support care management, program requirements and expectations, and access to available resources. These documents can be translated from English to the priority languages identified by JCOD based upon the needs of clients.

1. Release of information – to authorize the disclosure of personal identifying information to the department to explore services available.
2. Client consent form – to authorize the release of personal identifying information to the department for the participation of services.
3. Referral forms – to refer clients for eligible and helpful services.
4. Support Center business cards – to access needed justice involved information and services.
5. Resource documents – to identify available resources for justice involved individuals.
6. Complaint and grievance form – To file a formal complaint with the department.

G. Policy on Untrained Interpreters

JCOD currently utilizes two contractual agreements to support translation service needs in the department, which provides interpretation services via telephone by a professional qualified human interpreter in Arabic, Armenian, Mandarin, Cantonese, Farsi, Hindi, Japanese, Khmer/Cambodian, Korean, Russian, Spanish, Tagalog, Thai, Vietnamese and all other languages, and through video remote interpreting for ASL. JCOD will work to develop and implement a policy, as applicable, in Fiscal Year 2025-2026 that outlines how the department will work with untrained interpreters to ensure clarity on their obligations pending training. JCOD would only rely on untrained interpreters if the existing contractual service were unavailable.

Section 5: Notification of Language Assistance

JCOD is committed to providing assistance in priority languages other than English and ensures that language support is available at all key points of contact with the public:

At Our Offices and Program Sites:
All JCOD client-facing locations will display signage in priority languages to inform visitors that language assistance is available. Staff are trained to identify clients’ preferred languages and use tools such as “I Speak” cards and phone-based interpreter services. Key forms and documents are translated into priority languages to support access.

Over the Phone:
When clients call JCOD, they are greeted by our phone system’s interactive voice response (IVR). Staff are trained to connect callers with interpreter services when needed.

Online:
Our website is available in English and Spanish and Service-related content can be translated into other languages by trained interpreters to support broader access to these services.

At Community Events:
JCOD staff will be trained to interact with clients in priority languages. Multilingual signs and translated materials will be available at events, and interpreters or bilingual staff will be available to assist LOTE participants and ensure inclusive communication.

Section 6: Monitoring Language Assistance Effectiveness

H. Evaluation of Language Assistance

JCOD has active contracts with two language service providers who provide translation services between JCOD staff and JCOD clients who receive information or services from the department. These providers provide translation services for over 200 languages, including American Sign Language and the rest of the department priority languages. These language providers employ trained language service providers with native-level proficiency who are evaluated on a continuous basis for accuracy, clarity and cultural sensitivity.

Up to 98% of JCOD clients’ preferred language is English or Spanish, and JCOD service sites also employ staff who are fluent in English and/or Spanish and who can assist clients who do not wish to wait for formal translation services.

The department’s care management system tracks clients’ preferred language and will be used by program staff to document LOTE services provided to clients. Data collected will be used to assess the frequency and effectiveness of these services, including whether participants received services in their preferred language in a timely manner, with findings presented to program staff and management in business intelligence dashboards and reports. Data will also be used to make adjustments and improvements to services based on feedback received. Additionally, JCOD is in the process of developing a customer satisfaction survey that will include questions related to receiving services in one’s preferred language, and the effectiveness of those services.

The department will also conduct annual audits and assessments to check for compliance with language assistance policies.

I. Complaint Process

Starting July 1, 2025, the department will have a dedicated page in the department website for submitting language access complaints, that will include an option to submit the Language Access Complaint Form electronically. Additionally, email and phone number information will also be provided on this site for clients who wish to speak to someone regarding the complaint. The language access complaint process will also be available on JCOD client facing sites. This will help the department to identify ongoing needs for language services and tools to address those needs.

When the department receives a complaint related to language access, the department will respond within 10 business days to gather detailed information about the complaint. Upon gathering all the necessary information, we will provide the client with a resolution to their complaint, aimed to occur within 90 days.

Clients will be provided with multiple channels for filing a complaint, including site-based office locations, phone number, email, and by speaking to staff, including staff at in-person locations.

You may file your complaint in the language of your choice, including: Cambodian, Chinese, Farsi, Korean, Russian, Spanish, Tagalog, Vietnamese
Once filled out, send the document to PIO@jcod.lacounty.gov

Section 7: Training

The department will train staff to help support LEP and LOTE clients. The training will provide an overview of the DLAP to ensure staff have the knowledge and tools needed to identify language needs and comply with legal and departmental requirements. The DLAP will be presented at department level staff meetings, staff will receive the DLAP through email, and it will also be available in the department’s internal SharePoint site. Changes to the DLAP will be communicated to staff in a timely manner.

Staff will also receive training on the following topics that could be important and related to language access.

• Implicit Bias
• LA County Anti-Racism, Diversity, and Inclusion Initiative (ARDI)

To ensure that the DLAP policy remains current and appropriate, JCOD will review the policy annually and make updates as needed.

Section 8: Community Outreach & Engagement

• Social media here: JCOD will make LOTE information available through its social media posts, including Facebook, Instagram, and LinkedIn. This will provide clients with resources and information on how to get services in languages other than English.
• JCOD has partnered with an ethnic media collaborative to widely distribute information about the department and raise awareness in other languages, including Spanish through audiovisuals, podcasts, and additional services with media partners.