The Dane County Department of Human Services (DCDHS) is committed to ensuring fair and meaningful access to its programs, services, and information. DCDHS will take reasonable steps to provide language assistance to individuals who need help communicating effectively in English, including individuals with limited English proficiency (LEP), and will ensure effective communication, reasonable accommodations, and equal access for people with disabilities in accordance with applicable law.[1]

DCDHS Mission

Provide access to effective, innovative, and evidence-based services and resources that support wellbeing, opportunities to thrive, safety, and justice to persons of all backgrounds.

DCDHS Vision

Empowered people thriving in safe, just, and caring communities.

DCDHS Legal Framework

DCDHS’s responsibilities may arise under one or more applicable federal civil rights laws, depending on the program, funding source, and service involved. These authorities may include:

• Title VI of the Civil Rights Act of 1964
• Section 504 of the Rehabilitation Act of 1973
• Section 1557 of the Affordable Care Act, where applicable
• The Age Discrimination Act of 1975
• Title II of the Americans with Disabilities Act of 1990, including 28 C.F.R. part 35, subpart H, regarding accessibility of web content and mobile applications

In April 2024, the U.S. Department of Justice issued a final rule under Title II of the ADA that establishes technical accessibility standards for web content and mobile apps offered by state and local governments. The rule adopts WCAG 2.1 Level AA as the technical benchmark, with some limited exceptions.
(public-inspection.federalregister.gov) [2]

Because Dane County is a local government entity, this rule applies to county web pages, online forms, PDFs posted online, service portals, and mobile apps provided by or through the county. The rule covers content offered directly or via contractual or other arrangements.

DCDHS Language Access Coordinators

DCDHS's dedication to enhancing language access services and resources requires full-time management and oversight of the department’s policies, procedures, and service delivery. Therefore, the Language Access Coordinators were hired to develop and implement policies and procedures that coordinate language services for DCDHS. This effort helps ensure compliance with relevant federal and state civil rights laws and aligns with standards for culturally and linguistically appropriate services and related best practices.  

Advisory Committee

The Language Access Advisory Committee was established to support and advise the Language Access Coordinators in developing and implementing policies and procedures that adhere to federal standards and enhance DCDHS language services. Each DCDHS division and program has representation on the committee. 

Committee members are chosen for their professionalism, cultural competence, and ability to identify cultural and communication gaps. They also understand the responsibilities involved in serving individuals whose preferred language is not English and those with disabilities, in accordance with relevant federal and state requirements. They are positioned to influence and enhance language access practices within their divisions or programs. Most importantly, members show a strong commitment to providing equitable access to services for diverse populations.  

In collaboration with the Language Access Coordinators, the committee will support improving the quality and accuracy of language services within their division and programs, and advocate for continual improvement of the Department’s language access infrastructure.

Best Practice Action Plan

To provide effective language access services, DCDHS must have the right tools, resources, and qualified staff. This includes informing community members of their right to request free language assistance and making sure DCDHS staff understand the importance of language access and their role in providing meaningful access to services. The Language Access Coordinators have identified the following strategies for DCDHS to implement in order to achieve effective language access.

Personnel Approved to Provide Language Assistance

The Language Access Coordinators collaborate with bilingual staff, certified and qualified interpreters, and POS (Point of Service) interpreter vendors. They help ensure DCDHS employs qualified individuals capable of providing accurate and proficient interpretation and translation from English into other languages and from non-English languages into English, as well as accommodations for communication disabilities.

Family/Friend Interpreters Restriction

DCDHS will not require individuals who need an interpreter to bring their own interpreter or depend on a family member, friend, or other accompanying adult to interpret or help with communication.

If someone who needs language access requests an interpreter through a family member, friend, or other adult, DCDHS will inform the individual that they can receive a qualified interpreter at no cost. DCDHS will respect the individual's choice to provide their own interpreter. If DCDHS determines that the chosen interpreter is not capable or suitable—for reasons such as concerns about accuracy, bias, confidentiality, privacy, conflicts of interest, or, in the case of a child, immaturity—DCDHS may provide its own qualified interpreter to assist with communication.

DCDHS should not depend on children to act as interpreters. An exception is allowed only in emergencies or when there is an immediate threat to safety or well-being, and no qualified interpreter or approved multilingual staff is accessible by phone, internet, or in person. 

Automated Translation Tools Restrictions

Automated translation tools, like Google Translate, should only be used in rare cases and only when waiting for a qualified interpreter.

Use of Online Translation Tools: Automated translation services (e.g., Google Translate or other AI-based tools) do not meet DCDHS quality assurance standards for translating essential documents. Additionally, these tools should not be used to translate protected health information or other confidential client data, as they are not HIPAA-compliant. Therefore, automated translation tools should only be used in critical situations and solely for limited, non-confidential communications when needed. 

When urgent situations require DCDHS staff to use an automated translation tool, the employee must seek assistance from qualified bilingual personnel, a qualified in-person interpreter, or a qualified telephone or video remote interpreter to verify, correct, or supplement the information as soon as possible.

Urgent Need Exceptions

In urgent situations, DCDHS staff might need to stray from standard language service practices to meet immediate needs. Urgent situations include protecting a person’s life, preventing serious injury, or safeguarding a significant property interest.

In these situations, DCDHS staff may use the most reliable informal interpreter available, such as a family member, friend, or bystander, to gather immediate relevant information. Staff should be aware of the risks associated with informal interpretation, including miscommunication, bias, and potential conflicts of interest. Once a qualified interpreter or other appropriate language assistance becomes accessible, staff should return to standard best-practice language access policies and procedures

Monitoring Language Access Compliance

Language Access Coordinators continuously monitor and track DCDHS staff use, quality, service gaps, and improvements through evaluations, invoice records, and staff training.

DCDHS encourages managers and supervisors to assess language access use across offices and identify staff who speak or use a common non-English language within Dane County, so their position can be evaluated and considered for bilingual designation. The process begins by contacting Language Access Coordinators or the Community Partnerships and Employment Specialist in the Tamara D. Grigsby Dane County Civil Rights Department and the DOA’s Employee Relations Division and Inclusion to review and initiate a formal designation process, which starts with language proficiency testing.

Language Access Coordinators provide a safe, accessible way for individuals to submit complaints or grievances about language access services. This includes concerns about miscommunication or potential negative outcomes involving staff, clients, or interpreters when language assistance resources were used. To start the process, email Language Access at hslanguageservices@danecounty.gov.  

Language Access Trainings

Language Access Coordinators will conduct an annual series of training sessions for DCDHS staff to clarify legal responsibilities related to language services and to promote the consistent, accurate provision of language assistance and communication accommodations for individuals who use languages other than English and individuals with communication disabilities. Coordinators will also develop and deliver additional training, as needed, to address emerging concerns, strengthen staff practice, and maintain compliance with applicable federal, state, and local requirements.

The goal is to ensure that all staff can confidently follow best practices to promptly identify and serve clients who may need language assistance or communication accommodations.

Below is a list of available language access trainings designed to support department staff in providing equitable, inclusive, accessible, and legally compliant services across DCDHS.

Sources

[1] Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d; U.S. Department of Justice, “Commonly Asked Questions and Answers Regarding Limited English Proficient (LEP) Individuals,” LEP.gov; Americans with Disabilities Act of 1990, Title II, 42 U.S.C. §§ 12131–12134; 28 C.F.R. § 35.160; and U.S. Department of Justice, “ADA Requirements: Effective Communication,” ADA.gov. (lep.gov)

[2] U.S. Department of Justice, “Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments,” ADA.gov, describing the April 24, 2024 final rule under Title II of the Americans with Disabilities Act adopting WCAG 2.1 Level AA as the technical standard for covered web content and mobile apps, with limited exceptions. (ada.gov)

[3] Wisconsin Statutes sec. 16.70(8), “Wisconsin Municipality.”