HUD HCV Guidebook § 4.5

After completing the four-factor analysis and deciding which language services are appropriate, the PHA needs
to develop a Language Access Plan or implementation plan. Although PHAs have flexibility in developing this
plan, it will likely be most appropriate and cost-effective to periodically update the plan in consideration of
potential changes in immigrant populations of the jurisdiction. The plan may be in writing and address
training, administration, planning, and budgeting.

Small PHAs with limited budgets and resources that serve very few LEP persons may choose not to develop a
written plan; however, the PHA is still obligated to ensure meaningful access by LEP persons and may
consider an alternative way to articulate its plan.131

Some helpful steps in developing a plan include:
    •   Identifying LEP individuals who need language assistance, showing what data the PHA used to make
        this identification;
    •   Identifying the vital documents and services that are affected;
    •   Identifying types of language assistance that will be provided;
    •   Reviewing the PHA’s budget and assessing costs;
    •   Training staff;
    •   Providing effective outreach to the LEP community;
    •   Providing notice to LEP persons of which services are available and that the services will be provided
        free of charge; and
    •   Implementing process for determining when new documents, programs, services, and activities need
        to be made accessible for LEP persons.

The Department of Justice has developed a self-assessment tool that can be obtained at
https://www.lep.gov/sites/lep/files/resources/2011_Language_Access_Assessment_and_Planning_Tool.pdf

130 Final LEP Guidance at 2,744—45.
131 Final LEP Guidance at 2,745—46.

Fair Housing and Nondiscrimination Requirements                                                          36
US Department of Housing and Urban Development                                                   April 2025