TO:All IV-D Agents and StaffCSM No. 72

Division of Child Support

FROM:Mark S. Cornett

Acting Director

DATE:April16, 2007

SUBJECT:Language Access Section(LAS) Policy

The purpose of this memorandum is to provide clarification regarding the Cabinet for Health and Family Services’ (CHFS) policy on contracting official access to the Language Access Section’s internal resources, and also to provide updated information. Contracting officials are contractually required to provide language access services to their limited English proficiency (LEP) clients, but contracting officialsdo not use CHFS internal resources.The LAS is available to contracting official staff to help establish LEP protocols and identify local resources. The LAS Web site contains all pertinent information, including policy and procedure (revised November 14, 2006) and may be accessed at

The interpretation resources available to contracting official staff are as follows:

CHFS Approved Community-Based Partner Interpreters. The LAS tests and trains individuals across the state to deem them qualified as Community Partner Interpreters for CHFS. This resource can provide interpreter services for Spanish andother languages, as well. These individuals are freelance interpreters and can be utilized by contracting officials. To access this resource on the LAS Web site, click on“Interpretation Resources,” and then click on “CHFS Approved Community-Based Partner Interpreters.”

NOTE: The rates listed on the LAS website for CHFS Approved Community-Based Partner Interpretersmay only be valid internal to the Cabinet.

Language Line Services, Inc.® Contracting officials may open an account with Language Line Services under the Kentucky State Government account with Kentucky State Government listed as the parent company, and the contracting official’s office listed as the organization under the parent company. Contracting officials will receive the same rate as state government. Billing will be as a separate organization.

Below is a cost comparison of state government rates and standard rates for interpreter services.

Cost comparison:

Setup:KY-$100Standard-$200

Monthly fee: KY-$0Standard-$50

Spanish language:KY-$1.35/minStandard-$2.20/min

Other languages:KY-$1.50/minStandard-$4.50/min

CSM No. 72

April16, 2007

Page Two

The Language Line Customer Profile provides instructions for setting up an account with the Language Line. For additional information, contact Language Line Services by telephone at 1-888-763-3364, by fax at 1-800-648-0170 or online at Attached below are the following documents: Language Line Cost and Fees, Language Line Phone, Language Line Phone Q&As, Language Line Customer Profile, and a Language Line Phone Order Form.

Contracting officials may use other resources not included in the CHFS Approved Community-Based Partner Interpreters and Language Line Services, Inc. if:

  • They do not ask or require clients to provide their own interpreters.
  • There is no conflict of interest on the part of the interpreter (i.e. friends/family members).
  • They have taken reasonable steps to assess and ensure the competency of the interpreter.

To help clarify contracting official responsibilities, the paragraph below is provided from the LAS Web site. Click on “Procedures on Providing Language Access to Customers with Limited English Proficiency (LEP)” on the right side of the page to view the entire procedure.

Contractor Responsibilities

As sub-recipients of federal funds through the Cabinet and to ensure that services are delivered to customers identified as having limited English proficiency (LEP) when delivered by a contracted vendor, Cabinet contractors are required to ensure meaningful access by providing language assistance services that result in accurate and effective communication at no cost to LEP clients, patients, and/or beneficiaries. Such language assistance services are to be provided in accordance with the guidelines set forth in the U.S. Department for Health and Human Services “Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons.” The Language Access Section of the Cabinet is available to assist contracted vendors in identifying and developing appropriate language assistance measures.

Cross Reference

CSM No. 58, Update on Providing Services to Limited English Proficiency (LEP) Clients (5/19/06)

CSM No. 67, Updated Interpreter Listing for Limited English Proficiency (LEP) Clients (10/5/06)