HUD HCV Guidebook § 4.2

PHAs are required to take reasonable steps in providing LEP services to ensure meaningful access to their
programs and activities by LEP persons. HUD guidance provides for an individualized assessment that
balances four factors:
    1. The number or proportion of LEP persons served or likely to be encountered in the eligible service
       population by the PHA;125
    2. The frequency with which LEP persons come in 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 the PHA and the costs involved.

After conducting the above analysis, the PHA may determine that different language assistance measures will
be sufficient for different programs and activities. Some activities, particularly compulsory activities such as
reexaminations, will be more important than others and have a greater impact on LEP persons, and would
therefore require more language assistance. Language assistance means that a PHA provides LEP persons
with oral interpretation services, bilingual staff, telephone service lines interpreter, written translated services,
notices to staff and recipients of the availability of LEP services, or referrals to community liaisons proficient in
the language of LEP persons. PHAs have adopted innovative ways to ensure they are meeting their LEP
obligations. For example, some PHAs partner with other agencies in the jurisdiction to provide language
assistance materials and other services to reduce costs. PHAs also have adopted technology that can help
communicating with LEP individuals or hired bilingual staff to act as interpreters and translators.

This is a flexible and fact-dependent standard; however, this does not minimize the PHA’s obligation to serve
the needs of its LEP populations. These four factors must be applied to the various types of contact PHAs
have with the public to assess language needs and identify reasonable steps to take to ensure meaningful
access for LEP persons.126