hakim ouansafi barbara arashiro executive assist ant …€¦ · hakim ouansafi executive director...

DAVID Y. IGE

GOVERNOR

STATE OF HAWAII

HAWAII PUBLIC HOUSING AUTHORITY

1002 NORTH SCHOOL STREET

POST OFFICE BOX 17907

HONOLULU, HAWAII 96817

HAKIM OUANSAFI

EXECUTIVE DIRECTOR

BARBARA E. ARASHIRO

EXECUTIVE ASSIST ANT

IN REPLY PLEASE REFER TO:

16:0ED-015

March 3, 2016

Ms. Helena Manzano Executive Director Office of Language Access 830 Punchbowl Street #322 Honolulu, Hawaii 96813

Dear Ms. Manzano:

Please find enclosed the Hawaii Public Housing Authority's Language Access Action Plan (Plan), adopted on October 6, 2015, as the agency's submission required under Section 321 C-4, Hawaii Revised Statutes. This Plan is effective for the period October 1, 2015 through September 30, 2020. However, the Plan will be updated as necessary using the four-factor analysis.

Please note that the Hawaii Public Housing Authority previously adopted the Department of Human Services' Language Access Plan until the adoption of a Language Access Plan that details the plan for language access specifically for the programs administered by the Hawaii Public Housing Authority, which is an administratively attached agency of the Department of Human Services.

We would also like to take this opportunity to thank you for the services of Rebecca Gardner, Senior Legal Analyst, in her ongoing assistance with the Hawaii Public Housing Authority's 2016 employee language access and language access plan training.

Should you have any questions, please contact Ms. Kiriko Oishi, Compliance Officer, at (808) 832-4680.

,m(yt / �kim Ouansafi

�v, executive Director

Enclosures

AN EQUAL OPPORTUNITY AGENCY

HPHA Language Access Action Plan (Plan) October 1, 2015 - September 30, 2020

Language for Limited English Proficient (LEP) persons can be a barrier to accessing important benefits or services, understanding and exercising important rights, complying with applicable responsibilities, or understanding other information provided by the Hawaii Public Housing Authority's (HPHA's) programs. In certain circumstances, failure to ensure that LEP persons can effectively participate in or benefit from federally-assisted programs and activities may violate the prohibition under Section 601 of Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, which provides that no person shall "on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance[,]" and Title VI regulations against discrimination on the basis of national origin. Recipients of federal financial assistance have an obligation to reduce language barriers that can preclude meaningful access by LEP persons to the federally assisted public housing program. In addition, failure to take reasonable steps to ensure meaningful access to services by LEP persons may also be a violation of the state Language Access law (Chapter 321 C, Hawaii Revised Statutes).

The recommended actions in this Language Access Action plan are based on the balancing of

the following four factors:

(1) The number or proportion of LEP persons eligible to be served or likely to be served by

the HPHA's programs;

(2) The frequency with which LEP persons come in contact with the programs;

(3) The nature and importance of the program, activity, or service provided by the programs

to people's lives; and

(4) The resources available to the PHA and costs.

The four factor analysis is attached as Attachment 1.

To provide language assistance to LEP persons, the Hawaii Public Housing Authority (HPHA)

will:

1. Provide oral and written language interpretation services to applicants and clients that

are free of cost to them.

a. Oral interpretation

i. Each branch, section, and office of the HPHA will arrange for the

provision of oral interpretation or reading assistance in response to the

needs of LEP individuals in all face-to-face encounters when necessary to

provide the LEP individual with equal access to HPHA's services, when

requested, including at the following types of encounters:

Applications Office: at preliminary and placement interviews;

HPHA Language Access Action Plan {10/1/2015-9/30/2020) 1

Section 8 Subsidies Programs: at preliminary and placement

interviews conducted by the HPHA and at informal hearings;

Public housing management: at placement and recertification

interviews, orientation, and informal meetings concerning violations;

Hearings: at grievance and eviction hearings;

Public hearing: at public hearings to comment on the PHA plan or

proposed changes to administrative rules;

Relocation advisory services: at large or small group meetings and

individual meetings regarding relocation benefits;

At any office, when needed to access, discuss, request, dispute, or

receive information relating to any other right that is not listed above,

that a program participant is entitled to;

Individual meetings regarding complaints about the programs or

services provided by HPHA; and

On a case-by-case basis at large-group tenant meetings organized by

the HPHA or agent of the HPHA, depending on the subject matter of

the meeting.

ii. Each branch, section, and office of the HPHA will arrange for the

provision of oral interpretation in response to the needs of LEP

individuals, in telephone encounters. If an initial telephone encounter

reveals the need for extended discussion, the LEP individual may be

called into the relevant office for a face-to-face encounter, as may be

requested for any non-LEP individual.

iii. When mailing notices, letters, and other correspondence that affect

applicant/tenant benefits, to individuals who have self-identified as LEP,

the correspondence should include the form notice that 1. the notice is

important, and 2. the recipient is requested to contact the

manager/section if they need to have the notice translated. This form

notice should be made available in the languages most commonly used

by the applicants/tenants/program participants in that program. In

addition, whenever feasible, the envelope used to mail the

correspondence should have the stamp on the outside of the envelope

that indicates that the notice is important.

iv. A LEP individual's language assistance needs may be ascertained in the

following ways:

Verification of completed DHS5000 in client file;

HPHA Language Access Action Plan (10/1/2015-9/30/2020) 2

x. HPHA contractors will be advised and monitored relative to their

responsibility to provide interpreter services free of cost to the LEP

individual.

xi. The HPHA may assist in the coordination of providing competent

interpreters at tenant association meetings, but the tenant associations

should use their own funds for the cost of paid interpreters. Tenant

associations are encouraged to work with community groups and

organizations to help provide language access at their meetings.

b. Written translations

i. When available, translated documents created by HUD will be retrievedfrom www.hud.gov/offices/fheo/promotingfh/lep.cfm.

ii. Translation of written vital documents will be provided in conformancewith the law as follows:

The PHA will provide written translations of vital documents for each eligible LEP language group that constitutes 5 percent or 1,000 persons, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered; or

If there are fewer than 50 persons in a language group that reaches the 5 percent trigger, the PHA need not translate vital documents, but provides written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of vital documents, free of cost to the LEP person.

iii. Frequently encountered languages for purposes of the eligible LEP

language groups are as follows:

Chuukese, Cantonese, Korean, Mandarin, Marshallese, and Vietnamese

iv. For voluminous documents, it may be effective to provide written

translations of the most important or relevant portions of the document.

v. It is not practical, realistic, nor cost-effective to expect to provide a written

translation of every document that affects a client's benefits. Further, it is

not desirable for the preparation of written translations to delay the

provision of notice to the client. Therefore, especially when time is of the

essence, or written translation is impractical, it is advisable to provide the

notice in English, and include a notice to the client that the letter is

important and to call the number on the letter for oral interpretation of the

notice. (Appendix C) If the notice is brief, oral interpretation using a

telephone interpreter or bilingual staff may be cost-effective.


vi. Sight translation or reading assistance shall be sufficient to meet a

request for translation of non-vital documents relating to the loss of a

benefit or service.

vii. Staff should email translated documents to the Compliance Office for the

development of the translated documents database, which can be used

by other offices to translate similar documents at a lower cost. This

database will be made available on the Y: drive.

2. Provide oral interpreters who are competent and qualified to serve as interpreters.

a. Use bilingual/multilingual staff or a volunteer staff interpreter when available and

only for situations that do not require a professional interpreter.

b. If a bilingual staff member is not available, use the services of a competent paid

interpreter. The HPHA, not the LEP individual, will select the interpreter. If an

interpreter in the requested language is not available on the island, use of a

telephone interpreter is an acceptable method of interpretation if the LEP

individual consents. If a telephone interpreter will not meet the needs of the LEP

individual, as may be the case for certain languages that use facial cues or

gestures, video conferencing shall be used.

d. The HPHA will not encourage clients to use friends and family members as

interpreters.

e. Friends and family members who are under the age of 18 years may not provide

interpretation.

f. Friends and family members who present conflict of interest or confidentiality

concerns may not provide interpretation.

g. If, after the offer of a free interpreter, a LEP individual elects to use a family

member or friend, determine whether the volunteer interpreter is competent to

provide the service by having the volunteer interpreter complete the OHS 5050

form (Appendix 0). The HPHA does not provide compensation to any volunteer

interpreters. If the volunteer interpreter does not appear to be competent, the

HPHA should provide an interpreter in place of, or if appropriate, in addition to

the person selected by the LEP individual. Competency of the volunteer

interpreter may be determined by the answers to the questions on the OHS 5050

form, or prior experiences with the volunteer interpreter. Fluency in two

languages does not necessarily equate to good interpretation skills. If any of the

answers to the first two of the following questions for oral interpretation, or any of

the four questions for sight translation are less than "excellent", the volunteer

interpreter may not be competent:

i. I can communicate in English and the language listed above.


ii. I can interpret to and from English and the language listed above.

iii. I can translate written English to the language listed above.

iv. I can translate the written language listed above to English.

h. All volunteer and paid interpreters are required to review and sign anacknowledgment of the Interpreter Code of Ethics for providing interpreterservices. (See Appendix D) HPHA staff should take care not to allow theinterpreter and the LEP person to engage in conversation outside of theinterpretation service provided. Acknowledgements will be retained in thetenant/applicant file. If the same interpreter is used by one office on a regularbasis, one acknowledgment may be filed. The tenant/applicant file will notewhich interpreter was used at each meeting.

i. Updated interpreter lists will be distributed to each branch, section, and office.(See Appendix E for current listing.)

j. Performance of all paid interpreters will be reviewed by HPHA employees, andreports may be discussed by the HPHA Language Access Task Force.

k. The HPHA retains its right to hire an interpreter of its own choosing even if aclient brings their own interpreter. If the encounter involves the tenant's rights orbenefits under HPHA's housing programs, the HPHA must retain its owninterpreter for HPHA's benefit, even if the client brings their own interpreter. Thisdoes not preclude the client from bringing their own interpreter.

I. If a LEP individual requires language assistance on a telephone call, the staffshall determine the language spoken by the LEP person and if bilingual staff inthe language requested cannot be summoned to assist:

i. If the handset in use has third-party calling capabilities, the LEP individualmay be placed on hold while a paid telephone interpreter is contacted toassist with the call; or

ii. If the handset in use does not have third-party calling capabilities, thestaff shall collect the LEP caller's name and contact information to returnthe call with a competent interpreter. Any offices that do not have thirdparty calling capabilities must assess their telephone system capabilitiesand submit in their upcoming budget request funding for third-party callingcapabilities.

When placing the caller on hold, staff shall play music or repetitive message to indicate the caller is on hold.

m. CTS Language Link is a telephone interpreter vendor currently used by manyHPHA offices. The vendor's number is 1 (877) 650-8027. The HPHA accountnumber is 9540. The HPHA staff user's first and last name, as well the language

HPHA language Access Action Plan (10/1/2015�9/30/2020} 6

required is needed to get an interpreter on the line. All staff must have a blue

quick reference note near their phones to refer to in the event a telephone

interpreter is required. Guidance is provided in IOM 15-C0-1. (See Appendix F)

3. Collect and maintain client LEP information and status about LEP populations who use

HPHA services or have the potential for doing so.

a. The HPHA collects language needs information from each new applicant and

tenant, and from existing tenants at annual recertification (See Appendix G for

OHS 5000 forms). This information will be kept in the applicant/tenant paper file

for easy access to the individual's language needs. Upon upgrading of the

HPHA database, the HPHA will integrate client language needs into the database

system.

b. The HPHA will determine whether a visitor to an HPHA office is a LEP individual

by prominently displaying an 11lf you need an interpreter ... " poster in their office,

and referring the visitor to the poster if the individual appears to be having

difficulty communicating with the office staff. (Appendix 8 "Point here if you need

an interpreter ... " poster)

c. If the HPHA has difficulty determining what language a LEP individual speaks,

the "If you need an interpreter ... " poster or 11 1 speak" cards may be used,

(Appendix H "I speak" cards) or the telephone interpreter service may be used to

determine the language spoken by the individual.

d. The HPHA will determine whether an applicant or tenant is a LEP individual by

asking all individuals to complete a OHS 5000 form (Appendix G). This form is

available in Chinese, Chuukese, llocano, Japanese, Korean, Marshallese,

Samoan, Spanish, Tagalog, and Vietnamese. These forms are available on the

Y: drive at Y:\0998_PUB\COMPLIANCE OFFICE\OHS 5000 OFFER

ACCEPTANCE OR WAIVER. Clients should be shown the form in different

languages to allow them to select their language. If a translated form is not

available in the requested language, oral interpretation may be necessary to

explain the form until a written translation of the form is made available.

Completion and retention of this form is especially important when the LEP

individual elects to decline a free interpreter. A LEP individual may change their

election at any time by submitting a new OHS 5000 form.

e. The HPHA collects LEP encounter and interpreter usage information to assess

the LEP status and language assistance needs of current and potential HPHA

clients. Each encounter between HPHA staff and LEP individual(s) must be

logged and reported on a semi-annual basis. The sample log and reporting tool

is attached as Appendix I. This information is reported to OHS, which in turn

reports the information to the Office of Language Access, as required by law.

Reports are due to the Compliance Office on the 15th of January and 15th of


August for the previous 6-month period from July 1 through December 31 and

January 1 through June 30 period, respectively.

4. Train HPHA employees on Language Assistance Services

a. OHS Compliance Staff provides training materials for language access. HPHA

Supervisors are responsible for directly training on an annual basis all staff who

have daily or weekly public contact, and new employees.

b. HPHA contractors are responsible for training their own employees on both state

and federal laws regarding language access, and HPHA policy and procedures

on language access. The HPHA may provide HPHA training materials for

reference.

c. Each branch, office, and section will allow time for training front-line and

supervisory staff on HPHA's language access efforts.

d. HPHA supervisors will be encouraged to attend such workshops as "Role of

Interpreter" and "Serving LEP Individuals" provided by the Office of Language

Access, and other webinars, video conferences, and attendance at statewide

meetings designed to meet access needs. Supervisors or trainers will be

responsible for training new employees and all individuals under their supervision

who have daily or weekly public contact.

5. Monitoring sub-recipient compliance

a. All sub-recipient contracts will include the following language to ensure vendor

compliance with the provision of language access:

The Contractor shall perform the basic property management functions, including

implementing and complying with the HPHA's Language Access Policy and Plan

which provides for language assistance to limited English proficient program

participants. (For property management contracts.)

The Contractor shall provide services under this contract in compliance with Title

VI of the Civil Rights Act, Executive Order 13166, August 11, 2000, and Chapter

321 C, Hawaii Revised Statutes, which prohibit the denial of benefits and

discrimination on the basis of race, color, or national origin in any program or

activity receiving Federal financial assistance, or retaliation, and requires

recipients of federal funds to take reasonable steps to ensure meaningful access

to their programs and activities by LEP persons. This requires the Contractor to

have a Title VI and Language Access Policy and Plan. HPHA may at any time

request to review the policy and plan documents. (All contracts.)

6. Coordinate language assistance services.

a. The HPHA Compliance Office will serve as the Language Access Coordinator for

the HPHA. An HPHA Language Access Task Force has been established to


help implement this Plan. Each branch/section/office has a designated liaison as

follows:

PMMSB - Kaui Martinez

APPS - Michi Kanoura-Hatae

Section 8 - Diane Johns

Hearings Office - Renee Blondin-Nip or Marisa Pirtle

Information Technology Office - Marc Orbito

CMB - Sahar Ibrahim

CM - Kenneth Sasaki

PERS - Shirley Befitel or designee

PEO - Benjamin Park

CPO - Tammie Wong

b. The HPHA Compliance Office/Language Access Coordinator will represent the

HPHA on the OHS Access Task Force, with the HPHA Personnel Office as back

up to provide continuity.

c. The HPHA Compliance Office may make unannounced site visits to observe

notices, and other areas relative to language assistance services to gauge HPHA

compliance with this Plan. Contract monitors will report findings for contractor

provision of interpreter services for HPHA clients they serve. Findings from

these visits and reports may be discussed with Language Access Task Force for

follow-up.

d. The HPHA Discrimination Complaint process may be used for complaints by

applicants, tenants, and program participants regarding language assistance.

(See Appendix J.)

7. Definitions

"Bilingual staff'' or "multilingual staff'' means HPHA staff (or staff employed by a company contracted by HPHA to perform management services) who has demonstrated proficiency in both spoken English and at least one other language and who can effectively provide direct service in those languages using any specialized terminology necessary for effective communication. A staff member who only has a rudimentary familiarity with a language other than English shall not be considered "Bilingual/Multilingual Staff''.

"Oral Interpretation" or "Interpretation" means the act of listening to something in one language and orally translating it into another.


"Person with Limited English Proficiency" or "LEP person" means a person who does not speak English as his or her primary language and who has limited ability to read, write, speak, or understand English in a manner that permits him or her to communicate effectively with the PHA and have meaningful access to and an equal opportunity to participate fully in the federally assisted public housing program, and includes public housing program applicants and tenants and their household members.

"Sight translation" means interpreting during which the interpreter reads a document written in one language while converting it orally into another language.

"Vital documents" means generic widely used written materials of the PHA including:

• Notices advising LEP persons of free language assistance;

• Application forms to participate in the PHA's federally assisted public housing program;

• Written notices of rights, denial, loss, or decreases in benefits or services;

• Written notices of hearings;

• Notices of eviction; and

• Leases and project rules.

"Volunteer staff interpreter'' means HPHA staff (or staff employed by a company contracted by HPHA to perform management services) who has demonstrated proficiency in both spoken English and at least one other language and who can interpret accurately, impartially, and effectively to and from such language and English using any specialized terminology necessary for effective communication, but whose main job responsibilities are other than interpretation. A staff member who only has a rudimentary familiarity with a language other than English shall not be considered "Volunteer Staff Interpreter''.

"Written translation" or "translation" means the replacement of a written text from one language into an equivalent written text in another language.

This Language Access Action plan is required by Administrative Memorandum, Programs, No. 2, and Chapter 1, Section F, of the Admissions and Continued Occupancy Policy for the federally assisted public housing program, and shall apply to all HPHA programs. This Plan covers the period October 1, 2015 through September 30, 2020, and addresses the HPHA's continuing commitment to enhancing access to services. The provisions of this 2015-2020 plan shall remain in place until a revised plan is adopted.

Attachment 1: Four factor analysis

Appendix A: IOM 14-C0-10 HPHA Volunteer Interpreter Program

Appendix B: "Point here if you need an interpreter'' poster

Appendix C: Letter insert


Appendix D: OHS 5050 volunteer interpreter form and Code of Interpreter Ethics

Appendix E: Interpreter listing

Appendix F: IOM 15-C0-1 Update to IOM 11-C0-05 Regarding Free Interpreter Services for

LEP Individuals

Appendix G: OHS 5000 Offer and acceptance of free interpreter form

Appendix H: 11 1 speak" cards

Appendix I: Sample LEP encounter log and reporting tool

Appendix J: HPHA Discrimination Complaint process

Appendix K: Administrative Memorandum, Programs No. 2, Language Access Policy

Appendix L: Relevant Statutes


Four Factor Analysis

December 15, 2014 The Hawai'i Public Housing Authority

Background

On January 22, 2007, the U.S. Department of Housing and Urban Development (HUD) issued its "Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition against National Origin Discrimination Affecting Limited English Proficient Persons" to clarify recipients' obligations to Limited English Proficient (LEP) persons. This document provides an analytical framework that recipients may use to determine how best to comply with statutory and regulatory obligations to provide meaningful access to the benefits, services, information and other important portions of their programs and activities for individuals who have limited English proficiency.

To meet its obligation to take reasonable steps to ensure meaningful access to its programs and services, a PHA must conduct an individualized assessment that balances four factors to determine the extent of language services that the PHA will provide:

Factor 1: The Number or Proportion of LEP Persons Served or Encountered in the Eligible Service Area

The likelihood that language services are needed will reflect the actual number of LEP persons in a particular service area as well as the proportion of the population that they make up. Ordinarily, persons "eligible to be served, or likely to be directly affected by" a recipient's program or activity are those who are served or encountered in the eligible service population. This population will be program-specific, and includes persons who are in the geographic area that have been approved by HUD as the recipient's jurisdiction or service area. Recipients should "examine their prior experiences with LEP encounters," "latest census data for the area served, data from school systems from community organizations, and data from state and local governments[,]" focusing on the "lack of English proficiency, not the ability to speak more than one language."

Factor 2: The frequency with which LEP persons come in contact with the program

"The more frequent the contact with a particular language group, the more likely the need for enhanced language services in that language. If an LEP individual accesses a program or service on a daily basis, a recipient has greater duties than if the same individual's program or activity contact is unpredictable or infrequent. But even recipients that serve LEP persons on an unpredictable or infrequent basis should use this balancing analysis to determine what to do if an LEP individual seeks services under the program in question. Recipients should also consider whether appropriate outreach to LEP persons could increase the frequency of contact with LEP language groups."

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Factor 3: The nature and importance of the program, activity, or service provided by the

program to people's lives

"The more important the activity, information, service, or program, or the greater the possible consequences of the contact to the LEP persons, the more likely the need for language services. Decisions by HUD, another Federal, State, or local entity, or the recipient to make a specific activity compulsory in order to participate in the program, such as filling out particular fonns, participating in administrative hearings, or other activities, can serve as strong evidence of the program's importance."

Factor 4: The resources available to the recipient and costs

A recipient's level ofresources and the costs that would be imposed on it may have an impact on the nature of the steps it should take. "Reasonable steps" may cease to be reasonable where the costs imposed substantially exceed the benefits. Recipients should carefully explore the most cost-effective means of delivering competent and accurate language services before limiting services due to resource concerns. (Large entities and those entities serving a significant number or proportion of LEP persons may find it useful to articulate, through documentation or in some other reasonable manner, their process for determining that language services would be limited based on resources or costs.)

This Four Factor Analysis necessarily implicates the "mix" of LEP services the recipient will provide. The correct mix should be based on what is both necessary and reasonable in light of the Four Factor Analysis. Regardless of the type oflanguage service provided, quality and accuracy of those services can be critical in order to avoid serious consequences to the LEP person and to the recipient. Recipients have substantial flexibility in determining the appropriate mix.

Next, the HPHA reviews each of the Four Factor Analysis steps and supporting demographics as it applies to the HPHA programs and services.

Analysis

Factor 1. The number or proportion of LEP persons eligible to be served or likely to be served by the HPHA's programs

1. Publicly available data on persons eligible to be served

Because of the fluid nature of language ability and other statistical limitations, it is difficult to determine with precision the number of LEP individuals eligible for agency services. However, U.S. Census data can be used to generate a rough figure to represent the eligible population. Calculation of this figure and this factor's import are discussed below.

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I. Income Eligibility: A substantial number of Hawai 'i households are eligible for HPHAprograms

Table IA below shows the HPHA's current yearly gross income requirements for its Federal Public Housing program. Note that the eligibility requirements are expressed in the form of household income rather than individual income, and also that the eligible household income figure varies by county and depending on the number of people in the household.

TABLElA

Income Limits for Low Income Federal Public Housing

Household Size O'ahu Hawai'i Kaua'i Maui

1 $54,850 $39,100 $48,450 $47,600

2 · $62,650 $44,700 $55,350 $54,400

3 . $70,500 $50,300 $62,250 $61,200

4 $78,300 $55,850 $69,150 $67,950

5 $84,600 $60,350 $74,700 $73,400

6 . $90,850 . $64,800 $80,250 $78,850

7 $97,100 $69,300 $85,750 $84,300

8 $103,400 $73,750 ;$91,300 $89,700

9 $109,600 · $78,200 $96,800 $95,150

10 ·$115,900 $82,650 $102,350 $100,550Source: http:/iwww.hpha.hawaii.gov/faqs/publichousing.html

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Table lB illustrates the HPHA's current yearly gross income requirements for its State Public Housing program. The numbers are applicable statewide. The "Admission" column indicates the

maximum income that a household may have for admittance to the program. The "Continue Occupancy & Displace" column shows the maximum income a household may have without losing access to program benefits.

TABLE1B

Income Limits for State Public Housing

Household Size Admission Continue Occupancy & Displace

1 $33,300 $53,250

2 $38,050 $60,900

3 $42,800 $68,500

4 $47,550 $76,100

5 $51,350 $82,200

6 $55,150 $88,300

7 $58,950 $94,350

Source: Hawai'i Public Housing Authority

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Table IC shows the HPHA's current limits for its Section 8 Housing Choice Voucher ("HCV") program. As this program is only available on O'ahu, there are no columns for the other counties.

TABLE IC

Income Limits for the HPHA's Federally-Funded Section 8 Housing Choice Voucher Program

Household Size O'ahu

1 $26,100

2 $29,800

3 $33,550

4 $37,250

5 $40,250

6 $43,200

7 $46,200


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Table ID shows the HPHA's current income limits for its State-funded Rent Supplement Program. As with Table 1 A above, each dollar amount indicates the maximum income that a household may have and still qualify for the program.

TABLE1D

Income Limits for State-Funded Rent Supplement Program

Household Size Honolulu Hawai'i Kaua'i Maui County County County County

1 $41,400 $42,200 $44,400 · $48,400

2 $58,750 $48,200 $50,750 $55,300

3 $66,100 $54,200 $57,100 $62,250

4 $73,450 $60,250 $63,450 $69,150

5 $79,350 $65,050 $68,550 $74,700

6 $85,200 $69,900 $73,600 $80,200

7 $91,100 $74,700 $78,700 $85,750


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Table 2 (below) shows the distribution of household income in Hawaii's four counties. Each dollar amount represents the income threshold for the block of earners indicated on the left. For instance, in Honolulu County, households earning greater than $ 135,086 per year are in the top 20% of households. Households earning less than $32,863 per year are in the bottom 20%. According to the 2010 census, the average household size in Hawai 'i is 2.89 people.

TABLE2

Honolulu County Hawai'i County Kaua'i County Maui County

Top 20% - >$135,086 Top 20% - >$95,941 Top 20% - >$115,411 Top 20% - >$122,328

Top 40% - >$89,439 Top 40% - >$58,754 Top 40% - >$72,251 Top 40% - >$80,699

Top 60% - >$60,630 Top 60% - >$35,324 Top 60% - >$45,045 Top 60% - >49,918 Top 80% - >$32,863 Top 80% - >$17,677 Top 80% - >$26, 198 Top 80% - >$28,532

Source: 2013 American Community Survey I -Year Estimates: "Household Income Quintile Upper Limits"

Eligibility for HPHA programs is not limited to very low income households. A comparison of the HPHA's income eligibility limits and state household income data reveals that, in fact, a large minority of Hawai'i households are currently eligible to apply for one or more HPHA programs, though many choose not to. While it is difficult to determine the precise number of households or individuals who are eligible for HPHA programs, the following examples are illustrative: In each of Hawaii's four counties, over 40% of households have incomes below the Federal Public Housing eligibility limit for a two-person household. Additionally, roughly one quarter of O' ahu households meet the income eligibility requirements to apply for the State-Funded Rent Supplement Program. The significance of these figures is simply that a large proportion of Hawaii's population - including LEP individuals from a wide range of economic backgrounds - are presently eligible to participate in HPHA programs, but only a minority of this eligible population chooses to do so. Furthermore, as LEP individuals are disproportionately likely to fall within the eligible income range, 1 we must take into account the fact that the pool of individuals potentially requiring language access service in Hawai 'i is large and diverse.

1 According to the 2010-2012 American Community Survey, the average income of households in which no one

over 14 speaks English was $45,750 - well below the state household median income of $67,500. (Source: U.S. Census Quickfacts)

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II. Identifying Relevant Populations: Hawaii's LEP population is linguistically diverse withno dominant language or cultural group.

According to the 2010-2012 U.S. Census American Community Survey, the number of persons in Hawai 'i who spoke English either "not well" or "not at all" was 59,160.2 By cross-referencing these census answers with answers about home country and language spoken at home, one can generate a complex and accurate demographic profile of Hawaii's LEP population. Table 3 shows the LEP population's breakdown by birth country and Tables 4A and 4B illustrate the breakdown by language spoken at home. Note that there is some ambiguity in the wording used to refer to language spoken at home. For instance, in Tables 4A and 4B, it is unclear whether persons who replied "Chinese," referred to Mandarin, Cantonese, or some other Chinese dialect. Additionally, speakers of Micronesian, Marshallese, and other languages were aggregated into the category, "Other Pacific Islanders."

It should be noted that "Limited English Proficiency" is not a black and white category; it is context-specific. Whether a person's English is proficient enough for language assistance to be unnecessary must be detennined on an encounter-by-encounter basis and is dependent upon factors such as exigency and the importance of the service being provided. For the purposes of analyzing census data, we have limited the definition of LEP persons to the 59,160 individuals in Hawai 'i who indicated that they speak English either "not well" or "not at all." The following tables illustrate the demographic profile of Hawaii's LEP population.

2 We recognize that in practice, "Limited English Proficiency" is a fluid and context-specific category; however, for

the purposes of analyzing census data, we have limited the "LEP" category to those who speak English either "not well" or "not at all."

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TABLE3

Source: 2013 American Community Survey

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TABLE4A

Ilocano 13,142 (22.2%) Japanese 8,043 (13.6%)

Tagalog 7,497 (12.7%)

Chinese (incl. Mandarin/Formosan) 6,629 (11.2%)

Korean 5,800 (9.8%)

Other Pac. Islander (incl. Micro./Marshall.) 4,538 (7.7%)

Cantonese 4,017 (6.8%)

Vietnamese 3,192 (5.4%) Spanish 1,701 (2.9%)

Laotian 870 (1.5%) Samoan 858 (1.5%) Thai 254 (0.4%) All Other Languages 2619 (4.4%)

Source: 2013 Amen can Commumty Survey

Note: Although national origin data does not directly correlate with English proficiency, it may elicit other relevant information pertaining to language ability and cultural trends. This analysis has included national origin data for reference.

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TABLE4B

Source: 2013 American Community Survey

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2. LEP Needs Information Gathered by the Agency

A. LEP Encounter Data

Infonnation collected by the HPHA may also shed light on the actual number of LEP persons in

the area served by the agency. Since mid-2010, the agency has maintained records of its

encounters with LEP individuals. The agency now has nearly four years of data to use in

predicting the frequency with which speakers of particular languages will be encountered in the future.

Between January, 2011 and June, 2014, the HPHA had a total of 3,843 LEP encounters with

speakers of 24 different languages. The three most frequently encountered languages were

Korean, Chuukese, and Cantonese, which together comprise over half of all HPHA LEP

encounters. The remaining frequently-encountered languages were: Samoan, Vietnamese,

Marshallese, and Mandarin. 3 No other language represented more than 1.4% of encounters.

TABLES


3 Note: Where HPHA data refer to speakers of"Chinese," the dialect in question is unclear.

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B. Interpreter Request Information

The HPHA Applications Office and Section 8 Rental Subsidies Branch includes in each

application packet, a form asking for the applicant's language needs. The following table shows

the number of interpreter requests received by the Applications Office and Section 8 Branch between mid-2010 and late 2014. The significance of this infonnation is that it demonstrates a

lack of English proficiency as determined by the applicants. Here, we see a concentration of language requests similar to the spread seen in our encounter data. Notably, speakers of Chuukese, Cantonese, Korean, Vietnamese, Mandarin, Marshallese, and Samoan are among the top requestors of both interpreters (spoken language) and translators (written language).

Spoken

Chuukese

Cantonese

Korean

Vietnamese

Mandarin

Marshallese

Tagalog

Samoan

Japanese

llocano

Laotian

Tongan

Thai

Chinese

Phonpeian

Spanish

Kosraen

Russian

Visayan

Serbian

Murjock

ASL

Total

Total applicants on this list

TABLE6

373

228

264

135

91

79

49

46

34

33

25

17

16

15

12

9

6

3

3

2

1

18

1459

1490

Written

Chuukese 373

Chinese 319

Korean 264

Vietnamese 135

Marshal Iese 79

Tagalog 49

Samoan 46

Japanese 34

llocano 33

Laotian 25

Tongan 17

Thai 16

Chinese 15

Phonpeian 12

Spanish 9

Kosraen 6

Russian 3

Visayan 3

Serbian 2

Murjock 1

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C. National Origin Data from Section 8

The HPHA Section 8 Rental Subsidies Branch collects national origin data from each applicant

family on a voluntary basis. Similar to birth county infonnation shown in Table 3, national origin infonnation is not necessarily an indicator of language assistance needs, but provides an

illustration of the possible language needs within the participant population.

TABLE 7

Country of Origin - Section 8 Participants (2014) CHINA, 77

a UNITED STATES

a NOT GIVEN

aFSM

•VIETNAM

a SAMOA

a MARSHALL ISLANDS


D. Interpreting the LEP encounter data

• PHILIPPINES

CHINA

OTHER

Analysis of the HPHA's LEP encounter data reveals a striking disparity between the spread of

LEP requests and the demographic profile of Hawaii's LEP population (Tables 3-8). The LEP

individuals who seek out HPHA services are not predominantly members of the largest LEP groups in the state. Particularly notable is the relatively small number of encounters from the top three LEP groups, who are of Filipino and Japanese origin. Collectively, LEP persons who speak Ilocano, Tagalog, or Japanese at home comprise nearly half (48.5%) of the state's LEP population. Yet our encounter data show that these groups collectively comprise only 7.4% of all LEP encounters. This underrepresentation, while not inherently problematic, requires additional attention and vigilance on the part of this agency, as discussed below.

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