The Secretary of Labor and Industry has overall responsibility for the Department of Labor and Industry's Limited English Proficiency Program.
The Deputy Secretaries oversee Workforce Development, Unemployment Compensation Programs, Safety and Labor-Management Relations, Administration, Vocational Rehabilitation and Compensation and Insurance are responsible for the administration, overall management, operation, implementation, and assurance of compliance with Title VI of the Civil Rights Act of 1964, Limited English Proficiency requirements within their organizational areas.
Each Deputy Secretary has the responsibility for ensuring that programs and services under their jurisdiction are accessible to Limited English Proficient persons.
Each Deputy Secretary has the responsibility for ensuring that programs and services under their jurisdiction provided through contractors, grantees, and sub-recipients are accessible to Limited English Proficient persons.
The Director of the Office of Equal Opportunity is responsible for overseeing the Department of Labor and Industry's compliance with Title VI of 1964, Limited English Proficiency federal and state statutory provisions and for designating and providing guidance to the Department's OEO/LEP Committee.
The policy charges the Department of Labor and Industry's Office of Equal Opportunity with the responsibility for:
- Providing LEP guidance to Labor and Industry program offices
- Providing training to LEP Program Contacts
- Monitoring and ensuring consistency of each L&I specific guideline
- The central collection and review of all L&I's LEP Plans
Consistency among Labor and Industry's federally assisted programs is particularly important. Inconsistency or contradictory interpretation of this guidance may cause confusion and needlessly increase costs without rendering meaningful access to LEP Persons.
As with most government initiatives, this requires balancing several principles. While this guidance discusses that balance in some detail, it is important to note the basic principles behind that balance. First, the Department of Labor and Industry, herein referred to as "L&I", must ensure that Federally assisted programs aimed at Pennsylvania residents do not leave some behind simply because they face challenges communicating in English. This is particularly important because, in many cases, LEP individuals represent a substantial portion of those encountered in federally assisted programs. Second, L&I must achieve this goal while finding constructive methods to reduce the costs of LEP requirements on sub contractors, training providers and non-profit organizations that receive Federal financial assistance.
This guidance does not address communication issues covered under the Americans with Disabilities Act (ADA) or other applicable laws, regulations, or policies.
This guidance addresses proficiency, not preference of language.
The Office of Equal Opportunity's LEP Program Committee is responsible for monitoring the development and implementation of an LEP Program Plan by individual programs and service areas department-wide to include the following:
- Streamlining L&I 's LEP efforts.
- Serving as the main contact for LEP related issues in L&I.
- Presiding at committee meetings with designated LEP Program Contacts.
- Providing LEP technical assistance to the L&I's LEP Program Contacts.
- Assisting L&I's LEP Program Contacts with developing an LEP Program Plan that meets the needs of their individual programs.
- Assisting L&I's LEP Program Contacts with developing training that addresses the needs of their individual programs.
- Assisting L&I's LEP Program Contacts in implementing LEP training as needed.
- Reviewing materials, publications, and procedures to ensure their compliance with Title VI.
- Working with the US Department of Labor's Civil Rights Center to resolve compliance issues related to the LEP provisions.
- Assisting L&I's LEP Program Contacts with developing ways to comply with LEP requirements that are cost efficient.
- Providing compliance reviews at State Employment Security Agencies and Local Workforce Investment Areas to facilitate
- Compliance with LEP federal requirements.
- Responding to internal/ external complaints related to the implementation of LEP regulations.
- Facilitating information pertaining to the Commonwealth's contracted services for language access internally and externally.
The Bureau's LEP Program Contact is responsible for coordinating and monitoring all LEP activities within the individual programs under their jurisdiction, such as:
- Developing an LEP Program Plan that meets the needs of their respective programs.
- Implementing their individual LEP Program Plan.
- Developing LEP training that meets the needs of employees within their respective programs.
- Monitoring all LEP related activities within areas under their jurisdiction.
- Working with offices and programs within their jurisdiction to resolve issues related to the provision of LEP services
- Informing the Office of Equal Opportunity's LEP Program Committee of new developments in the area of LEP.
- Providing any LEP information requested by the OEO/LEP Program Committee regarding the individual programs under their jurisdiction.