Introduction

The District is committed to facilitating educational access and empowerment for all students, while honoring their diverse language backgrounds and the primary languages of their parents/guardians. The Board and Superintendent recognize the necessity of providing consistent language access for speakers of diverse languages and those parents/guardians whose primary language is not English. Oral and written communication of vital educational information in the primary language of the parent/guardian contributes to robust family engagement and has a positive impact on student achievement, ultimately reducing opportunity gaps.

The following procedures are intended to implement Policy 4218, establish meaningful, two-way communication between the District and parents/family members with limited English proficiency, and promote access for such parents and families to the programs, services, and activities of the District.

A. Definitions

1. Persons with “limited English proficiency” are individuals who are unable to communicate effectively in English either verbally or in writing, or both, because their primary language is not English, and they have not developed fluency in the English language. A person with limited English proficiency may have difficulty in one or more of four domains of language: speaking, listening, reading, and writing. Staff are urged to remember that limited English proficiency may be context-specific—e.g., a parent may have sufficient English language skills to understand, communicate and/or exchange basic information with a teacher, but they may not have sufficient skills to communicate detailed, specific information needed in a particular context, like an IEP meeting, a 504 meeting, or a student discipline hearing.
2. “Primary language” means the primary language spoken by a student’s parent or guardian, or the predominant language spoken in the student’s home. Parents may have more than one primary language and/or dialect.
3. “Language services” refers to a broad spectrum of services used or required to facilitate communication and understanding between speakers of different languages, and typically includes interpretation and translation services.
4. “Interpretation” means the process of first fully understanding, analyzing, and processing a spoken or signed message and then faithfully rendering it into another spoken or signed language.
5. “Interpreter” means a spoken language or sign language interpreter working in a public school, as defined in RCW 28A.150.010, to interpret for students’ families, students, and communities in educational settings outside the classroom.
6. “Translation” means the process of communicating the meaning of a written source-language text into an equivalent target language text in such a way that the content of both texts can be considered the same.
7. “Qualified Interpreter” means an interpreter who is able to interpret effectively, accurately, and impartially, both receptively and expressively using necessary specialized vocabulary.

B. Staff

The Multilingual Department within Student Services will oversee the implementation of this procedure.

By the 2023-2024 school year, the Superintendent will designate a staff member to serve as the Language Access Liaison/Coordinator, who will monitor and facilitate compliance with state and federal laws related to language access and family engagement. The Language Access Coordinator’s name and contact information will be widely shared so parents, school staff, and community members may contact them to inquire about language access services.

All school administrators, particularly those who have the most interaction with the public, such as registrars and enrollment staff, certificated staff, and other appropriate staff as determined by the Language Access Liaison/Coordinator, will receive guidance on meaningful communication with parents/family members with limited English proficiency, best practices for working with an interpreter, how to access an interpreter or translation services in a timely manner, language services available within the District and other information deemed necessary by the Language Access Liaison/Coordinator to effectuate the language access plan and program.

Appropriate district staff, as determined by the Language Access Liaison/Coordinator, will also receive guidance on the interaction between Policy No. 4218 and the District’s policy on effective communication with students, families, and community members with disabilities.

1. Language Access Program – The District’s language access program will include completion of the following activities:
   1. Adopting or developing a language access plan that outlines how the District will identify language access needs, allocate resources, establish standards for providing language access services, and monitor the effectiveness of the language access program;
   2. Administering the self-assessment developed by the Language Access Technical Assistance Program of Center for Improvement of Student Learning, established in RCW 28A.300.130 for evaluating the provision of language access services;
   3. Using the guide developed by the Language Access Technical Assistance Program of Center for Improvement of Student Learning, established in RCW 28A.300.130 for developing, implementing, and evaluating the District’s language access policy, procedures, and plan. The processes for developing and evaluating the language access policy, procedures, and plan must engage staff, students’ families, and other community members in ways likely to result in timely and meaningful feedback, for example partnering with community-based organizations and providing translation and interpretation in languages that are understood by students’ families;
   4. Reviewing, periodically, the District’s language access policy and procedures to incorporate necessary updates;
   5. Collaborating with community-based organizations on how to work effectively with interpreters and families; and
   6. Reviewing, updating, and publishing, at least annually, information about the school district’s language access plan, policy and procedures, and language access services, including the need for, and spending on, language access services. The information must include notice to families about their right to free language access services and the contact information for any school district language access coordinator and any building points of contact for language access services. The information must be translated into common languages understood by students’ families.
2. Developing a Language Access Plan – The District will develop a language access plan for ensuring the district complies with the language access policy adopted by the board and all other language access requirements. The language access plan will establish the following:
   1. Who is responsible for implementing the plan, including district-level administrators, workgroups, committees, or other district and school staff who will be responsible for overseeing the language access work in the district and schools, developing and modifying the language access plan, establishing and implementing operational procedures (i.e., how staff may access interpretation and translation services), and monitoring and evaluating the effectiveness of the District’s language access plan and services.
   2. Staff training on the district’s language access policy, procedure, and plan, including the frequency, curriculum, and target personnel who will participate in the training.
   3. Identification of the language access needs in the district and the services that will be provided. The plan will include a list of the languages that students, parents, and families communicate in and the prevalence of those languages. The plan will also identify the languages in the district that vital publications most commonly must be regularly translated into, in alignment with this procedure.
   4. How the District will conduct outreach to parents and communities with language assistance needs and the actions needed to implement an effective system for gathering feedback.
   5. What resources will be allocated for the provision of language access services.
   6. A description of the timeframe, objectives, and benchmarks for work to be undertaken.
   7. The District’s approach to monitoring and evaluating the effectiveness of the District’s language access plan and services, and the district’s process for modifying the language access plan and operating procedures in response to feedback and changing language needs.
   8. In developing the language access plan, the District will adhere to the standards for providing language access services as outlined in this procedure and the policy adopted by the board.
3. Administering the Self-Assessment – In developing and modifying the language access plan, the District will use, when it becomes available, the self-assessment tool developed by the OSPI Language Access Technical Assistance Program of Center for Improvement of Student Learning, established in RCW 28A.300.130 for evaluating the provision of language access services. In implementing the self-assessment, the language access liaison/coordinator will engage with community members, leaders, and organizations that have the inherent knowledge about cultural and language access needs. The liaison/coordinator will re-administer the self-assessment on a periodic basis as part of the District’s monitoring of the effectiveness of its language access program.

C. Identification of Families Needing Language Access Services  

1. Upon student enrollment and periodically through a student’s education, the District will utilize a survey to identify parents/guardians who need language access services and the languages in which they may need assistance. The District enrollment process will provide an opportunity for parents/guardians to identify their preferred spoken and correspondence language(s). Online enrollment is available in English, Spanish, Chinese, and Vietnamese. In addition, Enrollment Services staff are available in the top languages (currently Amharic, Chinese, Oromo, Somali, Spanish, and Vietnamese) to support in-person enrollment as needed.
2. The District will maintain an appropriate and current record of students’ families’ primary language(s) and use that information to inform its language access plan and program. This data is available to staff in PowerSchool/PowerTeacher under “Demographics.”

D. Interpretation and Translation Services

1. The District will collaborate with community-based organizations on how to work effectively with interpreters and families.
2. As materials become available, the District will make reasonable efforts to implement the toolkit developed by the Language Access Technical Assistance Program of the Center for the Improvement of Student Learning, established in RCW 28A.300.130, including the self-assessment, guide, and best practices.
3. The District and each school will, consistent with Policy 4218 and procedure, provide free oral interpretation services to those parents/family members who require language services to communicate effectively during any interaction with the District that is significant to the student’s education. Additionally, the District and each school will provide free translation of vital documents as required below.
4. All interpretation and translation will be provided by competent professionals as demonstrated by certification or similar means. The District will take reasonable steps to ensure that interpreters and translators have the knowledge in both languages of any specialized terms or concepts to be used in the communication at issue, and that they have been trained in the role of an interpreter or translator, the ethics of interpreting and translating, and the need to maintain confidentiality.
5. The Parent is welcome to invite additional persons for support and that person may participate in discussions. Although a parent may decline the District’s offer to provide an interpreter, the district or school should consider whether having a qualified interpreter present as the communication lead is still required. Students and other minor children under the age of 18 may not serve as interpreters for school staff and parents during any formal or informal meeting or process.
6. The District will facilitate staff access to appropriate interpretation and translation services to communicate with parents and families with limited English proficiency consistent with federal and/or state law, Policy No. 4218, and this procedure. The District will strive to be aware of and plan for the language access needs within the district. For a planned program, activity, meeting, or event, staff should initiate the request for language aid or services at least five days ahead of time. The District or school will take steps to respond to such a request as soon as possible after it is received. For unplanned and urgent communication, staff should request language assistance and try to arrange for such as soon as it is known that language assistance is needed. If an interpreter cannot be found that day, the school or District should maintain open communication with the requester to schedule an interpreted meeting as soon as possible. If no interpreter can be present, District staff should utilize remote interpreting services to communicate with parents and families. The District will provide effective communication for students’ families who are deaf, deaf and blind, blind, hard of hearing, or need other communication assistance according to Superintendent Procedure 4205SP – Accessing Communication.
7. The following interpretation and translation services are currently available in the District:
   • District translation staff translates district-wide communications and vital documents in Spanish, Chinese, Vietnamese, Somali, and Amharic.
   • The District contracts with two companies to provide over-the-phone interpreters in over 350 languages. All district staff are authorized and encouraged to use this service. Directions for staff on how to access this service are posted on the District’s internal webpage.
   • Upon request the District will provide interpreters for district-sponsored events such as school board meetings.
   • Schools may use multilingual instructional assistants to translate documents for school buildings (principal newsletters would be an example). Multilingual instructional assistants may also be requested to interpret at family conferences or school events. However, the primary role of the instructional assistant is to provide instructional support.
   • Families can always request that a document be translated, and the District/school will provide that service free of charge. However, it may be that District/schools use an over-the-phone interpreter to explain the document.
   • For interpretation at parent/family meetings regarding IEP, enrollment, 504, discipline, truancy, or graduation, school staff should contact the Multilingual Department at (206) 252-0773 or languages@seattleschools.org.
   • ASL interpreters are available upon request. Staff should contact 504coordinator@seattleschools.org.
   • The District contracts to provide two-way machine/human translated text functionality in over 100 home languages.
   • The District homepage includes language tabs for Spanish, Chinese, Vietnamese, Somali, and Amharic. In addition, all content on District/school websites can be translated using the Google Translate feature. Key phrases are translated in the top five languages. District staff will be informed of when and how to access interpretation and translation services available within the District and the administrator responsible for ensuring the availability of such services. District staff may contact Multilingual Department staff by phone at (206) 252-0773 or languages@seattleschools.org with questions or concerns, or to obtain information or assistance regarding interpretation and translation services.
8. District administrators, including those involved with registration and enrollment, certificated staff, and other appropriate staff as determined by the superintendent, will receive guidance and information regarding:
   1. the rights of parents and families with limited English proficiency under state and federal law to language access services provided by the District;
   2. the importance of meaningfully and effectively communicating with parents and families with limited English proficiency;
   3. the most effective ways to communicate with parents and families with limited English proficiency regarding the District’s available language services;
   4. the importance of utilizing competent translation and interpretation services when communicating with parents and families with limited English proficiency;
   5. the availability of translation and interpretation services within the District, whether through in-person interpretation, telephonic services, online services, or videoconferencing;
   6. the mechanisms and processes for accessing translation and interpretation services when working with parents and families with limited English proficiency, including ensuring the correct language service is being accessed, checking for parent/family understanding once interpretation has commenced, and proper vetting of translations for audience-appropriate content; and
   7. the process for reporting concerns or complaints.
9. Interpretation Services: Whenever requested by a parent or families or whenever school staff or District officials can reasonably anticipate that interpretation services are necessary to meaningfully communicate with parents or families regarding important information about the student’s education or school activities, the District will provide interpretation services in accordance with this procedure.
   Interpretation services may be provided by an in-person interpreter or by electronic means, such as telephone or video conferencing.
   Upon five days’ notice that such services are required, the District will provide interpretation services at public meetings organized or sponsored by the District (e.g., board meetings).
10. Translation of Vital District Documents: The District will provide a written translation of vital documents for each limited English proficient group that constitutes at least 5 percent of the District’s total parent population or 1000 persons, whichever is less. Historically, those languages are Spanish, Chinese, Vietnamese, Somali, and Amharic. For purposes of this policy, “vital documents” include, but are not limited to, those related to:
    1. registration, application, selection, and enrollment;
    2. academic standards and student performance;
    3. safety, discipline, and conduct expectations;
    4. special education and related services, Section 504 information, and McKinney-Vento services;
    5. policies and procedures related to school attendance;
    6. requests for parent permission in activities or programs;
    7. opportunities for students or families to access school activities, programs, and services;
    8. student/parent handbook;
    9. the District’s Language Access Plan and Program and related services or resources available;
    10. school closure information; and
    11. any other documents notifying parents of their rights under applicable state laws and/or containing information or forms related to consent or filing complaints under federal law, state law, or District policy.
        
        If the District is unable to translate a document due to resource limitations or if a small number of parents require the information in a language other than English such that document translation is unreasonable, the District will still provide the information to parents in a language they can understand, such as through oral interpretation of the document.
        
        Written translations of vital documents by machine/computer translation programs will not be used without prior review and editing by a certified translator for those languages where testing for certification exists. For all languages where testing for certification does not exist, the District will use a qualified translator as determined by the District.
        
        All documents and information posted or issued by the District for parents and families should contain a notice in appropriate language(s) that free translation and/or interpretation services are available and how to request a free translation or interpretation of the document.
11. Translation of Student-Specific Documents: The District will take all reasonable steps to provide parents and families, in a language they can understand, a translation of any document that contains individual, student-specific information regarding, but not limited to, a student’s:
    1. health;
    2. safety;
    3. legal or disciplinary matters; and
    4. entitlement to public education, eligibility for special education services, placement in the English Learner Program, the Highly Capable Program, accelerated courses such as Advanced Placement, or any other non-standard academic program.
12. Alternatives to Translation: When translation for a document otherwise required to be translated is unavailable or cannot be done, such as an emergency, a school or District office will provide an attached notice to parents and families in appropriate language(s) that free translation and/or interpretation services are available and how to request a free translation or interpretation of the document.

  Providing Information to Parents and Families

• The OSPI Home Language Survey, included in the enrollment process for all students, notifies parents/guardians of their right to translation and interpretation services, provided by the District and free of charge to the student and parent(s).
• At the time of enrollment, the District will also ensure that information regarding available interpretation and translation services and the District’s complaint process is provided to all parents/guardians. District staff will take steps to provide such information in the primary language of the parent/guardian.
• A Language Access flyer, translated in the top nine (9) languages spoken by the parents/guardians of District-enrolled students, will be displayed in all District and school buildings and provided annually by all schools to parents/guardians in the first day packet. The Language Access flyer includes notice to families about their right to free language access services, the contact information for any District language access liaison/coordinator, and any building points of contact for language access services.
• The District will notify staff, at least annually of this policy. Staff will be regularly provided written guidance regarding how and when interpretation and translation services should be accessed, and such guidance will be updated as needed to reflect available services. Guidance will be posted on the District’s internal website.
• Parents and families will also be notified annually regarding the process for filing complaints through the District’s nondiscrimination policy and procedure if they believe that such services have not been appropriately provided.
• The District website will provide information in the top languages concerning the rights of parents to free translation and interpretation services under federal and state law and how to access such services.

E. The Collection and Analysis of Data

The District will annually collect and periodically analyze the following language access and language access service information:

• The language(s) in which each student and student’s family prefers to communicate;
• Whether a qualified interpreter for the student’s family was requested for and provided at meetings reported in OSPI’s Comprehensive Education Data and Research (CEDARS) student data system; and
• Other data on provision of language access services, as required by OSPI.

The District will submit the information collected as required by OSPI.

Beginning in the 2023-2024 school year, the District will provide an opportunity for participants in each interpreted meeting to provide feedback on the effectiveness of the interpretation and the provision of language access services.

F. Discrimination Complaints

Discrimination based on national origin, which includes language and limited-English proficiency, is prohibited. The language access liaison/coordinator will communicate with the District’s Civil Rights Compliance Coordinator. Anyone may file a complaint alleging discrimination based on language or the District’s failure to provide language access services using the discrimination complaint process outlined in Superintendent Procedure 3210SP.B.

Policy Cross References

• 4218 – Language Access

Revisions

• November 29, 2022

Approved

• October 4, 2017