State and Local Language Access Efforts Amid Federal Policy Shifts

This transcript was generated using AI and may contain inaccuracies. If you notice an error, feel free to email [email protected].

[00:00:02.03] - Jacob Hofstetter 

Hi everyone, welcome to today's MPI webinar entitled State and Local Language Access Efforts Amid Federal Policy Shifts. So my name is Jake Hofstetter. I'm a policy analyst with the Migration Policy Institute's National Center on Immigrant Integration Policy. We're so excited for the great panel discussion we have lined up for today. Just have a few items to go through before we dive into things. So just as a reminder for today to please use the Q&A function throughout the webinar as you have questions. You can put questions in throughout the webinar and we'll— I'll pull those together at the end and have a moderated Q&A for our panelists after the formalized panel is over. So I just wanted to take a moment to introduce the center within MPI that I work at, which is the National Center on Immigrant Integration Policy. So the focus of our center is, as our name implies, immigrant integration within the United States. And we take efforts to examine critical policy issues at the federal, state, and local levels within a number of key systems that you can see displayed on the slide, all of which are really critical for serving immigrants as well as their children.  

Our language access work has been ongoing for a number of years now. We do a lot of work at the federal level trying to understand federal policy on language access in the current context. As well as taking a lot of deep looks at the design and implementation of language access programs and policies at the state and local level as well, and more broadly, how states and local governments are seeking to respond to the needs of our increasingly multilingual public in the United States. We do a lot of focus on the design and implementation of language access policies and programs, as I mentioned, something we've done a large amount of research on over the past 5 years. One piece of which I wanted to just highlight for everyone attending the webinar. We had this report come out earlier this year entitled "New Frameworks for Language Access: Tracking the Expansion and Features of State and Local Language Access Laws and Policies." There's a QR code available on the slide as well as a link. My colleague Lisa will also drop that in the chat as well. In addition, Lisa will also be sharing two other recent written products from our work on language access that may be of interest, one of which is an explainer on the English executive order from March of last year, which we'll be diving into on this panel.  

And another is a report that we had come out on the implementation of state and local language access programs that really did a broad nationally-based interview study on how different states and localities are implementing language access laws and programs. So we're really excited for our panel today. And just to provide sort of some framing for the conversation for today. So the past year, has seen significant and rapid change in the federal government's policies and approach towards language access. And this is, of course, occurred amid broader disruptions and changes that have affected federal agencies, programs, funding recipients for federal programs, state and local governments, and the country at large. In terms of language access, this began most notably with the issuing of Executive Order 14224, in March of last year, which designated English as the official language of the country and made major changes to federal language access policy. This, along with subsequent actions by the Department of Justice and other federal agencies, has really had the effect of dismantling much of the policy framework that previously supported language access in federal agencies themselves and across the federal government. For state and local government agencies, community service providers, and other stakeholders that work on language access, this has meant a tremendous amount of uncertainty and confusion, particularly for government agencies and service providers that receive federal funding. 

However, longstanding civil rights requirements related to language access remain in place, and as ever, language access remains critical for a number of reasons, not limited to increasing the effectiveness of government programs and also promoting public health and safety. And in addition, even as we see these headwinds from the federal level and this broader federal withdrawal on language access, there are also opportunities for states and localities to support and expand their efforts to provide language access in both their services as well as communications. And this is precisely why we brought this panel together today to talk on this webinar, which is to really explore this new dynamic about how state and local stakeholders are and can navigate the challenging moment we find ourselves in, but also take advantage of the opportunities that it offers as well. So we have 3 great speakers joining us here today for the panel. The first is Michael Mulé. So Michael Mulé is an attorney with 20 years of experience enforcing federal civil rights laws with a particular focus on advancing the rights of people who speak or read languages other than English. For 15 years at the Department of Justice, he enforced Title VI of the Civil Rights Act of 1964 and related nondiscrimination laws. 

Before joining the DOJ, he worked to expand access for low-income clients who spoke or read languages other than English, had disabilities, or were deaf or hard of hearing in New York. Since leaving the Department of Justice in September, he has provided consulting and training on civil rights and language access. Our second, uh, panelist is Ana Paula Noguez Mercado, who was born and raised in Mexico City and is a trained attorney and strategist with over 20 years of experience advancing language and immigrant rights. She has worked across federal and state government, as well as with national community and grassroots organizations to develop person-centered, legally informed policies and programs that address systemic barriers. As the State Language Access Manager at the New Jersey Department of Human Services Office of New Americans, Ana Paula leads the implementation of New Jersey's statewide language access law, enhancing government services for all residents regardless of their language. Previously, she served as the inaugural Language Access Coordinator at the U.S. Department of Justice. Our third panelist joining us today is Jodie Stanley, who is the International Support and Language Access Coordinator at the Human Rights Department in the City of Greensboro, North Carolina. 

In addition to that role, Jodie is also one of the leaders of the Municipal Language Access Network, or MLAN, which is a network of over 700 members that brings together state and local government staff who work on language access from around the country. So we're so excited for our conversation today, and I think we'll just go ahead and dive right in. So my first question is for you, Mike. And as I mentioned sort of in my, in my intro, we have seen a flurry of changes from the current Trump administration related to language access. However, the legal framework around federal civil rights are that requires steps taken to provide language access remains in place. So I'm wondering if you could sum up what all of this means, all of these changes at the federal level mean for state and local stakeholders who are confused or concerned about the legal foundation for their efforts on language access. 

[00:07:03.10] - Michael Mulé 

Sure, Jake, and it goes back to what you started with. For me, the starting point is Executive Order 14224, or EO 14224. Like you said, it was signed in March, and the order did 3 key things. First, it designated English as the official language of the United States, but that designation only applies to federal agencies in the executive branch. It does not apply to other branches of the federal government or to state or local governments. That's really important. Second, it revoked Executive Order 13166, which had required federal agencies to develop and implement their own language access plans. And also issue guidances for federally funded entities to ensure they provide meaningful access for persons with limited English proficiency. And third, the third thing it did, it required the Attorney General to withdraw guidance that was issued under Executive Order 13166 and provide what was called updated guidance. So two key things the executive order did not do, and this is really important for this conversation. It expressly did not require any federal agency to stop providing documents or information in a language other than English. And secondly, and for our conversation especially about Title VI, it did not change Title VI or the obligations of recipients to comply with Title VI or any other nondiscrimination laws. 

That means Title VI, the legal basis for many language access provisions, remains fully enforced. It still requires state and local entities receiving federal funds to take reasonable steps to provide meaningful access. Neither an executive order nor an agency guidance document or a memo based on executive order can rewrite or change a federal law. It's just not possible. It also can't change a regulation or a court decision interpreting a law or regulation. So let's also look at what DOJ has said about Title VI, because I think this is important for this conversation. When DOJ rescinded its Title VI LEP guidance in April 2025 because it was required by Executive Order 14224, DOJ specifically told recipients that the underlying Title VI or civil rights obligations have not been changed. In its rescission notice on that, when it rescinded that guidance, it said, and I want to quote this, recipients of federal funds still have a, quote, continuing obligation to comply with Title VI, all applicable Title VI regulations, all applicable civil rights laws and nondiscrimination provisions. Why? This is because agency guidance cannot change federal civil rights laws. So after Executive Order 14224 and the rescission of the LEP guidance, state and local language access laws remain independently binding. 

I just want to say something related from the state of Washington. The Washington State Senate just last week explained it, explained it like this. On March 5th, they said this, and I just want to quote this: Executive Order 14224 does not require or direct any change in the services provided by any state agency, nor does it remove the underlying legal obligations to provide access for individuals with limited proficiency under Title VI or other federal nondiscrimination statutes. Not only did the executive order or guidance not change those laws, states—and I'm using Washington State as the most recent example—acknowledge the order did not make those changes. 

[00:10:38.23] - Jacob Hofstetter 

Thanks, Mike. That's super helpful, and that's a great transition as well to the state piece. I mean, I want to turn to Ana Paula here. So, you know, Mike mentioned state laws around language access, and New Jersey enacted its own language access law in 2024, and one that we detailed in our new report as well, and is one of now 13 states as well as the District of Columbia that have formalized cross-agency policies that address language access. So obviously you're in the midst of implementing the state law right now. Can you tell us about what that process has looked like in this new context that we find ourselves in? 

[00:11:13.18] - Ana Paula Noguez Mercado 

Yeah, thank you so much. And buenas tardes, everyone. Good afternoon. And thank you, Jake, and MPI for hosting this very, very critical session. So the law was definitely a very big milestone to meet community needs and protecting the rights in New Jersey, given the context that Mike just mentioned. It's important to take into consideration that New Jersey is actually one of the most racially and linguistically diverse states. We have about 1.2 million individuals that are 5 years and older that have reported writing, speaking, and understanding English less than very well. As many of you know, this is the definition of what is considered limited English proficiency. And overall, more than 30% individuals speak a language other than home, including me, per census data. So while the law passed in 2024, the reality is that implementation had been taking place in the background for quite some time. The Office of New Americans, where the Language Access Initiative sits, was created in 2020 under the New Jersey Department of Human Services and under the leadership of our Director Johanna Calle and former Commissioner Adelman. And as many of you might already know of some other ONA offices around the country, the mission includes connecting immigrants and refugees with supporting services. 

So from the get-go, language access was a priority, knowing how important it is for immigrants to be able to navigate state programs in, in their primary language. So very early on, the ONA partnered with Rutgers University. They help us develop a needs assessment and also an initial language access plan that was very, very helpful to identify gaps and assets that we have in the state. And those have been key to advancing implementation statewide at this moment. We, as the ONA, also contributed in shaping the legislation with some practical feedback and insights. So since the law passed, the law has been on creating a strong system, a strong infrastructure in the, in the state to ensure that the law is carried out effectively. And so the law requires Human Services, the Office of the Attorney General, and the Chief Technology Officer to help covered entities— what it's called, those entities that provide direct services to the public— and their language access coordinators follow the requirements of the law. And so we've been working together as a team, these three agencies, to launch and support this implementation process. The ONA has been taking the lead in coordinating across the governor's office and these lead agencies. 

And as the ONA, we have been focusing on strategy, seeing how the different pieces move, creating resources for language access coordinators and other language access designees like dedicated web pages, toolkits, training programs as well. And we're going to probably touch on later technical assistance to help agencies implement the law. I will be sharing in a little bit our, our first annual report for folks who are more interested in what that looks like in detail. OIT also launched a pretty impressive tech tool that includes a website widget translation that supports initial access to state websites and navigation on what information is available. It also developed a language access translation application that combines AI with required human in the loop for accuracy and quality. And the Attorney General's Office is making sure that agencies fully understand the requirements of the law and provide the necessary technical assistance. So with the support of these three state agencies, we've been working with the, the agencies across the state. We're working with 24 covered entities, and there's a lot of work to do. Of course, we have made significant progress, but as you said, Jake, we're just starting. The, the, we to understand that the law is not just a policy, but it's really a commitment to making services from the state accessible to everyone. 

[00:15:25.22] - Jacob Hofstetter 

Thanks, Ana Paula. That's a great, great summary of the work you've done. I'm really looking forward to digging into some of those pieces as we move through the panel as well. Now, Jodie, I want to turn to you for a local perspective coming from Greensboro, and I know you've been working on this issue in Greensboro for a number of years now. And, you know, as Mike mentioned, we have these— the civil rights law is still in place that requires language access. We've seen these state efforts as well. But I'm just wondering, like, from your perspective working at the local level in Greensboro, what have the effects of the federal changes around language access policy been on sort of your day-to-day work in the communities that you serve? 

[00:16:04.01] - Jodie Stanley 

Yeah, so as you know, we're one of those recipients of federal funding that Mike was talking about that have a continual obligation to provide the language access services. I was pleasantly surprised to see that Executive Order 14224 didn't have the impact that I thought it might at the local level. It did create a little confusion in pockets of people and parts of the community. Thankfully, really early on, it was MLAN, the participants of MLAN, it was you, Jake, it was Ben D'Avanzo. We were meeting early and often. We were able to, I feel like, develop consistent interpretation of the executive order. And some concise language about what it meant and its limitations. And that, I couldn't be more thankful because I was able to take that information back to my community. And I still bring it up in trainings. I still talk about it and bring it up as a talking point. Beyond Executive Order 14224, certainly other policy changes have impacted local law enforcement. I think first responders are reporting higher levels of anxiety. There's a general fear, a heightened fear of calling 911 to get help. From, from first responders. We've seen the other, the other changes. 

We've seen a marked decrease overall in the use of LanguageLine. This really surprised me. In the last 6 years since I've been tracking it, it has increased every single month, every single year, pretty steadily. May 2025 was the first decrease I've ever seen since I've been tracking this data. And to me, that's a potential indicator that some people in our community don't feel as safe to call as they used to, and that's of concern to the city for sure. So we're taking some some action around that. Lastly, I would say that one of the other big changes is that legal oversight and consultation has become a priority for us. It used to be something, you know, that was, it was often secondary, but it has become absolutely critical. 

[00:17:51.14] - Jacob Hofstetter 

Thanks, Jodie, for that perspective. And that's really interesting. I mean, and troubling to hear that you've seen this, this drop, this unprecedented drop in those asks as well. So, Mike, I want to turn back to you to ask another question as well, which is that we're still waiting on, as you mentioned, potentially getting more guidance from the Department of Justice on language access. And there also, I think, more broadly across the field seems to be some fear that the current administration might seek to dismiss or downplay the importance of providing language access, even if the civil rights requirements remain in place. And on an even further step, the administration might try to limit some of the work that recipients of federal funding or grants are doing around language access. Yet, you know, as we've heard from work in New Jersey and other places as well, this would run up against a lot of these state and local efforts, but also state and local laws and policies that exist to promote language access. So can you tell us a little bit more about how you think these competing requirements or what this might look like if it played out? 

[00:18:50.18] - Michael Mulé 

Yeah, sure, Jake. And it's a little bit of what I touched on before. But while we wait for guidance, and if it does come out, I think there's really kind of 3 key points about— and I think this is important generally for this conversation— about what an executive order or a guidance can and cannot do at the federal, state, and local level and to federal, state, and local laws. The first thing is an executive order cannot cancel or change a state or local law. So an order, an executive order, can only tell federal agencies in the executive branch how to operate. It can't even tell other branches of government. It can't direct the judiciary. It can't direct Congress. The same is true for guidance, however. Any guidance based on an executive order, it cannot change what a state or local law requires or remove any of its protections. State and local laws stay in place unless Congress passes a new law or DOJ or another federal agency goes through the full public rulemaking process to create a new law. So far, for the time period we're talking about, Congress has not changed Title VI. And also, more importantly, DOJ has not proposed any new Title VI regulations or any language access regulations. 

So that's the first point. There hasn't been any change in the law. Doesn't change any state or local laws. Secondly, the U.S. Supreme Court decisions have also really narrowed how federal agencies can use guidance. Which is all we have right now is guidance or a memo that only went to federal agencies. After the 2024 decision in Loper Bright, courts were told by the Supreme Court to no longer defer to an agency's interpretation of an unclear federal law. And in an earlier case called Kisor v. Wilkie, which dealt with agency regulations, the Supreme Court made clear in 2019 that agency guidance cannot be used to enforce new legal obligations or to impose, and this is what the court said, legally binding requirements. Again, guidance documents based on executive orders or executive orders cannot be used to create or take— create requirements or take away protections. And third, I just want to go to something that the Attorney General actually issued in February 2025. So this Attorney General— the Attorney General issued a memo that reaffirmed the following: guidance documents issued without formal rulemaking cannot modify the legal obligations of regulated entities. Well, who are regulated entities? 

State and local entities for our purposes here. So that is why when you look at something like the July 2025 DOJ guidance memo to federal agencies, it didn't change Title VI or the duties of state or local governments and entities. It doesn't have that authority. So even if— and going back to your question— even if an administration, this one or another one, signals a desire to scale back Title VI language access enforcement with an executive order or guidance, the underlying legal obligations have not changed. State and local entities still must follow Title VI and their own language access laws. Thanks, Mike. 

[00:22:01.19] - Jacob Hofstetter 

That's super helpful for clearing up that uncertainty and confusion there as well. So, Ana Paula, I want to turn back to you, and you had a little Easter egg in your answer that foreshadowed this question as well. But, you know, one of the key things you've mentioned as you're implementing this statewide law in New Jersey has been the extensive amount of technical assistance that's been provided to state agencies to— in order to help them have the full measure of language access requirements in place. So from our own research, we've seen that there are a lot of common barriers that government agencies and service providers face in actually making language access happen in their services and communications. So can you tell us a little bit more about what's sort of the most common technical assistance you've seen required? And then for those who might be running into these same issues on the call as well, what was effective in addressing those technical assistance needs? 

[00:22:53.06] - Ana Paula Noguez Mercado 

That's a great question, Jake. Implementing language access is not as simple as it might seem. Agencies face a range of challenges, right? And starting sometimes with just the basic awareness of what is language access, what is the difference between interpreting and translating? So that, that piece is critical, really having that understanding for folks who have to move forward with implementation of any, you know, like law or ordinance. Also, just understanding that with translation of one document is not enough, right? It's not about just like, oh, I'll translate this document, this flyer, and they will magically have access to everything else. It's really thinking about designing services, designing full systems that work for people from the moment they start the interaction with that agency to the end of their journey, and then to allow also for a warm handoff. Often people fall through the cracks, right? Like people fall through, through the lack of coordination between the different agencies. And this is why some of the strategies that we've been addressing in New Jersey have been very successful coordinating across different entities to create uniformity. Also, another big challenge is understanding the law itself, right? Like having a full understanding of what is required. 

And I'm, I'm sharing here in the, in the chat the, the law. I don't have time to go through the requirements, but for example, often we get the questions of like, what is a vital document, right? How do we prioritize this translation effort? How do we handle digital content to make sure that it's also accessible, right? So understanding also interpreting needs, you know, how to handle this type of events that you're organizing today with interpreting or in situations where real-time communication is critical. Budgeting is another challenge. You know, we often say you have to dedicate the funding that is necessary as an operational cost, right? Like the electricity, like any other computer software. Having dedicated full-time staff, right, as language access coordinators. These language access coordinators often are, you know, have full workloads and then they're adding 10% to their, you know, language access work. So it's definitely not a one-time investment. It should be regarded as ongoing. And so some of the things that have worked, as I was mentioning, having centralized places where people can— so as I mentioned, community of practices, where people can gather, the people who are leading this work at the different levels. 

So at the language access coordinator level, or maybe at the division level, at the program level, where people can get together, share these challenges, share lessons learned, learn some new resources, practical tools like web pages, centralized templates, workflows, training materials, etc., that will allow to really streamline the process of allowing this, this implementation to happen. Also, you know, talking about roles is very important to make sure that there's understanding that bilingual staff are not interpreters or translators, which often happens, right? Like people who are bilingual end up, end up doing everything language access related. And so having this strong infrastructure like hubs, centralized, providing guidance, creating tools, the community of practices, are solutions that have been very, very helpful to, to ingrain the, the, the, that culture change, right? Because it requires a culture change. It requires us thinking differently of, of, of how we see service provision and just providing one-on-one support, you know, really thinking about how these individuals can grow their work, can really build. We have included a lot of service design strategies and practical practices with the goal of building, as I was saying, frontline services that are fully supported with robust behind-the-scenes systems, right? 

So if you don't have the guidance on how to provide interpreting services, the person at the frontline staff will not be able to know how to do it, right? So you need to have the system in place. You have to have that vendor. You have to have the guidance. You have to have the policies so that the person gets the training and is able to provide the service when an individual walks in. So those are some of the, you know, the things that we've been using to tackle some of these common barriers. I, you know, of course things keep coming up. It's a team effort and having this community of practice and this collaboration with all the different lead agencies and the other entities we work with has made the difference. 

[00:27:49.01] - Jacob Hofstetter 

Thanks so much, Ana Paula, for all that detail. It certainly aligns with a lot of what I've seen in my own research. And Jodie, I'm sure you see a lot of these themes as well, both in your current work and at, at, at MLAN more broadly. And so Jodie, I wanna turn to you now because I think one thing that we've actually said to each other maybe a few times is that, you know, civil rights requirements are not the only reason to work on language access. They're a good reason, but they're not the only one as well. So can you tell me a little bit more about what benefits you've seen from Greensboro's efforts to provide language access to local programs? 

[00:28:18.10] - Jodie Stanley 

Yeah, I love how you give me partial credit for saying that, Jake, because it was 100% you that said it, that laws were never our best argument. So I want to push that back on you. That was, that was really instrumental in the way that I had to reframe my understanding of what was happening and how we can— this is actually a really great opportunity, right? It's a really great opportunity to dig in and talk about the benefits of language access beyond just the law tells us to do it. I think the local level, I've come up with 4. 3 talking points that I think most localities would agree with me on. The first is risk mitigation and efficiency. It is cost-effective to do it right the first time. I heard an example of a city that was doing a street widening project. They sent letters and got consent from every homeowner on the street except for one. So staff went out one afternoon to knock on the homeowner's door. A 16-year-old answered, and when they told him about the project and needing the homeowner's consent, he said, "My mom wouldn't understand anyway. She doesn't speak English." So they asked the 16-year-old permission to dig up the driveway apron, and he said, yes, sure, no problem. 

So you can imagine the mom's frustration when she came home from work. It turned into an expensive 2-year back-and-forth conversation between the city and the homeowner. If they had translated the letter and worked with an interpreter to communicate with the homeowner in the beginning, it would have saved so much time and money. It's always better. It's more efficient to do things in right the first time. The second thing is crisis response time decreases drastically and language access speeds up recovery. I can't think of a better example of this than COVID. It was so important to engage the entire community to prevent the spread and language access promoted recovery on the backend once the pandemic passed, for the most part. Language access enhances public safety. Proactively building public trust is foundational to especially police work, and it pays off in dividends. Also, in terms of public safety, we don't often talk about the benefits to the organization or first responders. For example, we often talk about language access as a favor for doing— we're doing for residents. But especially in public safety, we need to start reframing that. Language access is for the safety of first responders as much as it is for the safety of residents. 

And then the last one is, I think language access enhances accurate reporting. The census, think about the census, that data that goes into the census determines the amount of funding that goes into a community. So of course you want accurate reporting. And I just wanna revisit a point that Ana Paula was saying earlier. Language access coordinators aren't just experts on compliance. We're usually really accustomed to working with a shoestring budget. The number one argument or pushback I hear is we don't have money. We can't afford it. We don't have money to pay that service. We can help you find ways to cut costs that are still— they still fall within compliance. We don't expect you to know everything about this. We fully expect to guide you, to support you. So I really strongly encourage everyone to lean on your experts, lean on your friendly neighborhood language access coordinators, and then of course MLAN can also be a really strong support mechanism for that as well. 

[00:31:30.20] - Jacob Hofstetter 

Awesome. Thanks so much, Jodie. So, Mike, I want to turn to you for sort of our last series of questions here. So Jodie mentioned there's this opportunity amidst the uncertainty and confusion for states and localities. And localities and especially states might actually have more ability to work on language access than they think. So from your perspective, what can states and localities do with their own laws and with their own authorities to advance language access that seems promising to you right now? 

[00:31:58.06] - Michael Mulé 

Yeah, and I agree with that, and I agree that, you know, New Jersey, you know, what Jodie and her teams are doing in Greensboro really demonstrate this key point, which when you think of federal civil rights laws like Title VI, they set a national minimum for language access protections, but they do not limit state or local governments from going further. I think that's a really important point. They are a floor, not a ceiling. So unless Congress clearly says otherwise, if you are a state or locality, you are free to strengthen civil rights protections for people who need access to programs or activities in a language other than English. You can go beyond that minimum. Title VI is a minimum. It's the minimum federal national standard. You can go beyond that. And because states and localities can always do more, they can use their existing authorities. And there are a lot of existing authorities a state and local entity has. They can create new laws, um, and they can create, uh, greater language access protection. Some examples: they can adapt stronger language access requirements. They can adopt stronger language— they can enhance enforcement tools. They could expand the scope of who qualifies for protection. 

And importantly, in what we were just talking about as far as costs and resources, and they can invest in interpretation or translation services to meet community needs. Yeah, and that might mean taking part in larger contracts that allow for lower per-cost services, right? Instead of every single municipality contracting on its own, which usually costs more. And I want to give two recent examples because I know a lot has happened in the last year, but I want to share two recent examples of language access bills in state legislatures that were introduced this year, meaning since January. First, just examples of how people are pushing and improving and trying to expand. First, the Virginia General Assembly is now considering a bill that would require each state agency to have a language access coordinator, which we were just talking about those, and that language access coordinator would be required to create that agency's annual language access report. That's new. That wasn't a requirement before. That bill is currently in committee, but it's moving through. In Washington State, there's a bill that is now on the governor's desk, as someone noted in the FAQ, for signature. It's waiting for signature. 

That would create language access guidelines for public programs, activities, and services that all state agencies would be required to follow. Those are states, and those are states pushing beyond the bare minimum. Those are states using the authority they have to expand and improve access. And I think that's really the point. It is a minimum. You can go beyond that within your authority as a state, unless Congress tells you otherwise. 

[00:34:49.16] - Jacob Hofstetter 

Awesome. Thanks so much, Mike. So I just wanna be mindful of time, and Jodie and Ana Paula, I think this next question I'm gonna kind of combine for both of you so that we can move to the Q&A. So Jodie, I know you helped lead MLAN, and Ana Paula, obviously from your work in New Jersey. So just from your respective levels at the local level and the state level, what lessons would you offer for stakeholders who are coming into this moment, whether that's policymakers, legislators, government staff, advocates, or community service providers? So maybe we'll start with you, Jodie, if you don't mind going first on that one. Sure, for sure. 

[00:35:27.09] - Jodie Stanley 

Lessons we've learned is that connection with each other across the state used to be a benefit and it is now becoming mandatory. Policies are shifting so quickly. It's important for us to be connected to each other, to have a good understanding and be able to take that information back to our communities as quickly as the policies are coming out. Um, I think it's important to accept and embrace that understanding for the gravity of language access work is expanding, and that shows up in a lot of different ways that I won't go into detail about. I think thinking about this idea that languages are— other languages are scary in some way, shape, or form. Languages aren't scary. Navigating multilingualism is part of the essence of being human. A lot of countries navigate it. There are challenges that are realities, but they can be overcome. I had a fellow board member because I ran these responses by the MLAN board members to make sure that the responses reflect the team, not just me. And one of them said success is when the diversity of the program you're running matches the population in the community. So I think that's a good marker to think about when you're developing a program. 

Who is, who is participating? And does it reflect, you know, the community? Community engagement tied to language access is money and time saved. Once the storm hits, it is too late. It's really important to start thinking ahead, to start thinking proactively. About building that foundation of trust so that once the storm does hit, the community cannot only withstand, they can recover. Language access is a really important part of resilience. And for that reason, most MLAN board members agree that it's really going to be important in the years to come for leadership and at government levels to really start investing more in emergency management efforts. 

[00:37:15.17] - Jacob Hofstetter 

Thanks so much, Jodie. Great. And I really love that once the storm hits, it's too late. That's a great, great lesson to take from this. Ana Paula, same question for you on lessons. 

[00:37:24.12] - Ana Paula Noguez Mercado 

Yeah, I think definitely there's some overlap at the state level and building a little bit on what Jodie shared in terms of collaboration and community. I think really sharing the tasks of improving language access is not only something that relates to folks that are bilingual. It really benefits us all. As Jodie was saying, it makes the mission of each state agency to be more practical, more feasible, more achievable when you have the resources that you need to communicate with a population that you serve or that you're meant to serve, which includes individuals who don't speak English as their primary language. Also sharing, sharing lessons and sharing experiences. I think often And when there is a program that is being built, there's a sense of responsibility of like, I have to build it from scratch when there's so much already done. There's so many promising practices already developed. So really having the humbleness and just the ability to reach out and learn, even if it's like a sister agency, right? Or at the local level, you know, there's really incredible things that have been developed with a lot of creativity. So really looking into that, those doing, doing some research on that. 

As Jodie was saying, expanding languages. There is an idea the language access is English and Spanish, and, and our communities are much more rich and diverse than that. So really thinking about how are we addressing, you know, API languages and all kinds of languages, indigenous languages that often fall into into the, you know, like we don't have the data, we don't have the information. And so really thinking about that. And then I think a very important lesson when you're doing language access is that it's very important to think short-term, midterm, and long-term, right? You have to maintain working the system that you have in place because there's people who will be needing the services to be able to communicate on both sides, the staff person with, with the impacted individual. But also you want to think, have this vision of moving forward. What is this modern, modernized system, more functional, going to look like? What is, what is sustainable process? So it definitely requires continuous improvement, reviewing services, gathering data, adjusting over time, and really thinking about implementation looking forward, right? Like building the systems that will allow everybody to participate fully. As they say, when you design for individuals with LEP or individuals with disabilities, you're designing for everyone. 

And so starting from that, that principle is really some of the lessons learned and creating systems that don't just respond to compliance or implementation, but that will have real impact. 

[[FOR THE Q&A PORTION OF THE TRANSCRIPT, SPEAKERS ARE NOT IDENTIFIED BY NAME. PLEASE SEE THE RECORDING TO IDENTIFY SPEAKERS.]] 

[00:40:17.06] - Speaker 1 

Thanks so much, Ana Paula. That was super useful as well, and I'm sure helpful for all the folks working at the state level, but also the local level as they think about these issues. So we're going to move into the Q&A portion of the webinar at this point. We've been getting a lot of great, great questions coming in. Just as a reminder to please put whatever questions you have in the Q&A function, and we'll get to as many as we can in the time that we have remaining. So the first question I want to send to you, Mike, is that something that came up in the question that came up as well as in some of the questions we got before the webinar is this idea around like terms and conditions for federal grants and ways that that might be used to either prevent work on language access or to, for example, forbid the use of federal funds to work on language access as well. So I'm just curious what sort of thoughts or reflections you might have on that given your experience and expertise in this area. 

[00:41:10.13] - Speaker 2 

Yeah, Jake, I think of a parallel example. So people might be aware that over the last year, some entities had their funding taken away or threatened to be taken away, or they received new agreements with federal agencies that had new terms, and they disagreed with those terms. In almost all those cases, those terms were not successful, meaning that the, the entity either got its funding back or the terms were deemed to not be consistent with what is legally required. Adding terms at that point, for example, if you're a recurring recipient and then new terms are added, and there's no opportunity and there's no basis for it. So the terms I'm thinking of, there was this one example where the terms were based on another executive order that was passed in this administration, right? And the lawsuit— a lawsuit was brought against the federal agency, and the lawsuit said you can't add terms based on an executive order. You can only add terms if there's been a change in law or change in regulation, kind of what I was saying before. So the reason why the agency was not successful in that lawsuit was because the agency said we changed these obligations in these terms in this particular funding source because of an executive order. 

[00:42:19.05] - Speaker 2 

And of course, you can't do it on that basis. If you want to let people, if you want to make changes, there's ways you can do that. You can have new regulations, you can have requirements based on those regulations, but you can't say, oh, it's the same problem. You can't kind of change the contract based on a policy choice versus going through public comment and notice. Because of a change in regulation, because of a new obligation or new requirement. And the other thing with that case, which is what would happen here too, it can't be done midstream, right? Like, that's never been a requirement. That's never been a restriction. Imposing that restriction is really— we had no notice of it. So there's a bit of fairness about that too, not having notice of what that addition is going to be or what that means, and then having no legal basis for it. The case I'm thinking of, it was unsuccessful, and I think a similar thing would happen here. Did the statute change? Did the regs change? I know that discriminatory effect regulations were rescinded, but the statute didn't change. Like, you still have that obligation, and that's how we're going to meet that obligation to ensure compliance with Title VI obligations. 

[00:43:22.07] - Speaker 2 

And a condition can't be added based on that other case based on an executive order. So there's not a lot of— I mean, I know that's my frame as an attorney, but like, there's not a lot of legal basis why you can kind of add on things or restrict things. If there's no legal basis for those. 

[00:43:37.24] - Speaker 1 

Thanks, Mike. That's super helpful. And I imagine that ties into the point too of state and local laws that would, that would potentially bump up against some of these requirements as well, which you spoke on earlier. So another question from the Q&A for Jodie and Ana Paula, a piece about engaging community or making community, multilingual communities aware of that these services are available at the, within state and local governments. I mean, I think there's two pieces to this, one of which is whatever the policy and legal ramifications of changes at the federal level are, there are certainly effects that are occurring, cultural effects, social effects, effects that people are just feeling in their lives as well, which I think, as you mentioned, Jodie, can really impact folks' willingness to seek interpreting or translation or other language assistance. But in addition, I think there's also this concept of like, that I'm also— I'm a lot of times involved in, which is like building language access programs within government. But those are only as effective as they are plugged into the actual communities that need those services as well. So that was a very long question, but just I'm really interested in both of your thoughts of how do you engage community to really ensure that there is uptake or to make folks aware that these vast suite of services and resources are available at the state and local level? 

[00:44:52.19] - Speaker 1 

And why don't we start with Ana Paula? 

[00:44:54.14] - Speaker 3 

For that one. It's an excellent question, Jake. So 2 things, because the language access program sits within the ONA, we do have a number of different community support in, in language, right? So we have been very clearly implementing what we are, you know, walking the walk. Basically, we have a set of documents that are translated and we're modeling for other entities so that they can see the way that we're approaching the work so that they start incorporating it as well. So many of these documents that we have developed, for example, Know Your Rights documents and other, and other information have been shared with community. We have received input from community. And another piece that is important for your, I think the second part of the question that you asked, we have engaged with with community service providers. So case managers or entities that actually provide those support services to the, to the community so that they know what resources are available to them. So we have found that those folks who work as navigators just in general, you know, a member might come and, and with a letter that they don't understand, or just in general to be able to access services. 

[00:46:12.24] - Speaker 3 

We have been engaging with them, providing them the information so that they they can continue supporting the clients that they work with. 

[00:46:22.05] - Speaker 1 

Thanks so much, Ana Paula. 

[00:46:23.04] - Speaker 4 

Jodie? So this is where I think building that foundational work really came into play. The relationships that we took time, years and years to build with our community really have paid off in the last couple of years through COVID and also through this, right? The relationships, my job, is structured so that I do provide immigrant support as well as language access. And I am a huge fan of that structure. I think it's really important to have both. To your point, Jake, there have been a couple of things that we're really concerned about, specifically around not calling 911. We saw a spike in the number of domestic violence-related injuries, and there was one homicide specifically in Hispanic and Latino families. And they're, it's reportedly because of fear of calling for help. So we, we did some targeted work with the police department. In addition, we've been working closely with 911, county EMT, EMS rather. We've also been working with our behavioral health response team, fire and police. We're going to create a 5-part video series in probably 9 to 13 languages and will We're just informing people about the service. This is what happens when you call 911. 

[00:47:40.05] - Speaker 4 

This is what the operator is going to tell you. It's a free service. We don't ask for your immigration status. This is who we're going to send. It's really helpful to have your address in English when you call. Just really baseline things. And to be honest with you, the information is really great for English speakers as well. Some English speakers, I think we make the assumption that English speakers don't have this information. So in addition We also have what we call the International Advisory Committee. Greensboro is really proud of this body because it's the only one in the country that we know of that serves in a municipal advisory capacity. But this team is elected by Greensboro's immigrants. And so these are folks— it's a membership team of 5, and these folks are elected by immigrants and refugees in Greensboro to serve as their voice to city council. And it's incredibly effective. They're able to rally. They represent multiple communities across the city. And in a season like this, they've been really active and engaged, and we can't be more thankful. So when it comes to getting the word out to the community, these are the methods that we're using. 

[00:48:41.22] - Speaker 1 

Thanks so much, Jodie. And that really is an important model that you mentioned there. I know you've talked about that before in these contexts, and it's always such a great thing to lift up for audiences as well. So we had a really interesting question come in about accountability. And I think this is a great question when we think about, you know, we talk a lot about technical assistance, we talk about implementing language access programs, and here we're just focusing at the state and local level, but how accountability can play into that. And I want to ask all three of you about this. So maybe just starting with Ana Paula, like, how does, how do you see accountability mechanisms fitting into your work in New Jersey? Thank you, Jake. 

[00:49:18.22] - Speaker 3 

It's a very good question. We don't have a specific accountability mechanism included in the law beyond reporting. So we're using reporting as a way of having that accountability, right? Like making sure that it's not only providing technical assistance, but also ensuring that we're walking and accompanying the different state agencies in doing what they need to know to implement the law. So it's, you know, check-ins, you know, in certain periods of time, like quarterly, so that we can really build that desire or need to implement the law. In my past experience, it has been always very helpful to create meetings where people are responding or sharing their updates because it actually does create like a sense of competition. They want to share and they want to show that they are actually advancing the work. But beyond that, because of the limitations that we have in the actual law We don't have anything that has, you know, like more teeth to, to have folks, you know, follow a compliance process or mechanism. So I think there's, there's different ways in which you can really support individuals to be able to, to have that accountability. And again, using, using empathy, empathy, and, and this piece of like, like we need to make sure that this individuals should be able to go through their journey without any hiccups is part of the accountability to their mission, to the work that they're doing as state workers. 

[00:50:59.01] - Speaker 3 

Thanks so much, Ana Paula. 

[00:50:59.23] - Speaker 1 

That's super useful. And certainly that aligns with a lot of research we've seen. There's not always necessarily that mechanism that you can pull on accountability, and there's other means. I think reporting is a great, a great one that you raise. So, Mike, I wanted to get your take on this. You have, you know, years and years of experience really doing enforcement cases and working on language access at the state and local level. And we might not see those types of cases in the near future, but I'm just curious, like, what you think about in terms of accountability measures sort of at the state and local level. And also, are there any options there that folks might not be thinking about as well? 

[00:51:32.02] - Speaker 2 

Well, when Ana Paula was talking, the one accountability mechanism I was thinking of was one that actually helped us resolve a matter. So the open question was the entity didn't know how much it would cost to expand interpreter services. Right? So we didn't know, they didn't know. So what we came up with, and this is related to reporting, was for the next 3 months they were gonna track, they were gonna do a pilot program because that's an easier sell for a lot of entities to see how much it did cost and track how many times they did provide interpreter services. We didn't know and they didn't know what it would cost. We figured out what that would be, and that allowed them to do a projection because they were coming up on a budget year. And that projection based on objective numbers actually helped them secure the funding they needed because Absent that, they were just guessing, right? And what happened was in that particular example, what they guessed before, before we had the numbers was I think 3 or 4 times greater than what the actual number was. So it was also a really helpful way kind of doing this documentation of what it really cost. 

[00:52:32.10] - Speaker 2 

Two things. One, we got an objective number. It wasn't tainted by anyone's kind of political perspective, right? But two, they had a number to go to their legislature and actually get approved for the budget, cuz they said, based on what we saw, we can project for the year it's gonna be this. So I think that's an interesting way to think about reporting. It's just not reporting for reporting's sake. I know some people feel like that's what it is. It has real metric value for, oh, this is how many encounters we actually had with Haitian Creole speakers. We never had that before. Or this justifies my budget request for a 5% increase in interpreter services because We track that. So I think people need to think about it in that frame too. It actually can help you as a state or local agency. And that's the example I thought of when you were talking about reporting. It means more than just, oh, did you do the annual report? Right? There are other ways you can use those metrics to further and verify there is this need in our community. 

[00:53:29.23] - Speaker 1 

Thanks, Mike. That's super helpful. Jodie, I want to turn to you on this piece. I mean, so working in local government, I'm just curious what your perspective is on sort of around accountability and how that can be built out or what strategies you've used in that area. 

[00:53:44.09] - Speaker 4 

As someone put the complaint process in the chat, and I think that's a really important point to highlight, Jake. I have always talked about complaints as a positive. To me, if I'm getting a complaint, it means the community or someone within the organization— actually get most complaints from other staff members, employees that work for the city who know they've been trained well on language access. Requirements and what's supposed to happen. So I see complaints as nothing but a positive. It's an opportunity to offer additional training. What I'll do is I'll get that complaint and then I, you know, I work with that department to, to go in and kind of meet them where they're at, find out, do you have access to the resources that you need? Anapala mentioned empathy, and I think empathy for the end user, so the person that's, that's living here that may need access to the service, but also for staff. And this is just something that I've observed in working with adults and training adults is that we're not the best learners. We don't necessarily like to learn new stuff. It can often feel foreign. And when we're encountering something, an experience that feels jarring to us, we'll freeze up, right? 

[00:54:46.01] - Speaker 4 

We don't like it. And that happens to city staff sometimes. They're not equipped with the services. They don't understand why they're doing it. They haven't practiced. They don't feel, they don't feel equipped or capable. So we try to start there and have empathy for the experience of the staff member as well. So that's what I was thinking when y'all were talking about accountability. We also do a lot of reporting. And to Mike's point, the reporting has helped us argue the benefits of the bilingual pay incentive program, how much money we're saving, you know, our interpretation and translation that our staff are doing internally because they're trained annually on interpretation and translation ethics. I mean, it's— the reporting piece is super critical. 

[00:55:27.21] - Speaker 1 

Thanks so much, Jodie. So we have, I think, one last question that I really want to get all of your perspectives on. It might take us a little bit over 2:30, so just want to flag for folks, if you do need to drop off, the recording will be made available on MPI's website. We'll— our panelists have been gracious enough to stay on a few extra minutes to address questions. So I want— Something that's come up a lot in the chat, came up a lot in registrant questions as well, is artificial intelligence. And I, you know, I— this wasn't necessarily the topic the webinar was intended to address, but it always seems to come up in the language access space as well. So I'd love to just get all of your takes on sort of how you see this technology fitting into your work or the understanding of the field. And I'll send it to you, Mike, first for your response. 

[00:56:15.19] - Speaker 2 

The challenge for me was, and it was in the July memo last year, like, responsible use of AI. It left a lot of people confused what that meant. And then we saw in December of the last year how GSA said, the General Service Administration told federal agencies, don't use AI alone, make sure it's verified. I am still in that position. Using AI, especially for translation, alone without having it verified by a competent human translator, I think that is bad practice and it leads to poor quality. And I haven't seen a study that proves otherwise. The other thing I would say with AI is these conversations seem to happen after the product is already in place. I think the conversation needs to happen before that. I think the conversation needs to be, hey, vendor, can you verify the quality of this product when compared to a human equivalent who's competent in this or these languages? I'm not seeing people ask that question. I'm not seeing people ask vendors for a pilot test run in a real-world situation, not a quiet booth, but a real-world situation where there's a lot of people talking. How well does that work, right? 

[00:57:21.15] - Speaker 2 

What is the quality of the translation output when we actually assess it? Before I spend any of my agency's money, I want you to demonstrate for me in a pilot period it actually works. Yet a lot of times it's, oh, we bought this thing. How come it doesn't work? You need to get that before you sign the contract and have it in place. And I think a lot of this is just eagerness because it sounds cool and everyone else is doing it versus practically show me this works at a high quality level. And if it does, fine, but you have to demonstrate that before I'm going to put my resources into the product and put it in place. 

[00:57:57.01] - Speaker 1 

Thanks so much, Mike. Uh, before I, Jodie and Ana Paula, get your reactions to this, which will be our final question. I just want to flag for folks that again, the recording is going to be made available on our website. We're at the official end of the webinar, so I know that folks might need to jump off. Reporters can contact Michelle Mittelstadt with any questions as well. You can find all the details in the chat. But without further ado, Jodie, so what's your take on this as well, hearing what Mike had to say too? 

[00:58:20.14] - Speaker 4 

So we were in a conversation not long ago with an AI provider, and Lynn hosted this when AI was really becoming a hot topic. And I will never forget when we were talking, because the biggest question is about accuracy, right? Our biggest issue with machine translation is accuracy. And when we were kind of pummeling him with questions like, "Well, how do you test it? How do you know?" And he's like, "Well, how are you tracking the accuracy of your human interpreters?" And to me, I really appreciated the comeback because I think a lot of times, first of all, we need to be making sure that the humans that we're using are qualified and certified and trained regularly on interpretation and translation ethics. So I just wanted to throw that out there. But I mostly, I have resources for y'all if you want to go look at some folks who are doing really great work with like really thoughtful work with AI in language access. Kahlil Thomas in Philadelphia, I want to give him a shout out if he's not here. He's one of the most incredible. He's written this whole flowchart on the use of AI in translation, and he's very willing to share his work with most folks. 

[00:59:21.13] - Speaker 4 

But I do encourage you to reach out to him and ask permission. He does want us to, you know, give Philly credit for the work that he's done there. I encourage you, if you're not already, if you're a government employee, that you join MLAN. This is a conversation that probably comes up twice a week. We have an email chat. We go back and forth, who's doing what, have you tried this service? Checking in with other MLAN folks has been like a lifesaver for so many of us. It's really, really powerful. And the other example I want to offer is a 911 center in Texas. I haven't got their permission to share this with you, so— but I can put you in touch with the individual I learned about it from. This 911 center in Texas is actually using AI in addition to a telephonic interpreter. So in the 911 conversation, if it ever goes south or the operator feels like there's something that's not lining up or the AI is saying something different than the interpreter is saying, they know to flag that and they know that that's a real issue. So I love the idea. 

[01:00:17.16] - Speaker 4 

Mike mentioned it of using AI as a supplement, not as a standalone. 

[01:00:24.03] - Speaker 1 

Thanks so much, Jodie. So Ana Paula, final response of the panel. I'd love to get your take. 

[01:00:29.13] - Speaker 3 

Sure. Yeah. So, you know, as, as New Jersey, we're, we're, we're starting to scratch the surface and I will share on the link on the chat the link to our— I think I sent it. Yeah, our annual report. It has a little bit more information about the tech tools that our New Jersey OIT has developed. I agree with Mike. Definitely the use of AI has to come with a human in the loop, as I was mentioning, a human review, and also building on what Jodie said, making sure that the individual that's reviewing the output is a qualified individual. I think the problem often with AI is that individuals who, who are not bilingual or who are a little bit further away from like frontline staff might, might really think that by clicking you will get like a full translation, including nuances that are, you know, culturally sensitive. And part of it is education, educating how language works, how syntax works, what is cultural competency, how, you know, our languages are full of cultural context. We communicate our history, our personal history, our cultural history through language. So that cannot be related through AI. So this is where the human in the loop is so relevant, is so necessary to verify that a saying, you know, like, it's raining cats and dogs, you would not say in Spanish, esta lloviendo perros y gatos, right? 

[01:02:03.23] - Speaker 3 

It makes no sense, but AI would probably translate it like that. So really thinking about who is reviewing, when is the review process coming in, is it a last minute where you don't have time and it's going to be published? So really embedding, and what we've been doing in New Jersey is creating that education, providing guidance on what is a responsible and appropriate use from a linguistically, you know, and culturally competent manner. 

[01:02:32.22] - Speaker 1 

Thanks so much, Ana Paula. And I think that's a great point to wrap up on, on the intricacies of language as we're talking about language access. So I want to thank everyone for attending today. A recording of the webinar will be put up on our MPI events page eventually. If you registered as well, you'll also get a link there as well. I also just want to give such a, such a full thank you to our 3 panelists for joining us, sharing their experiences, their expertise. We deeply appreciate it, and I'm sure this has been immensely helpful for all the folks who attended and all those who will watch this event later as well. So thank you so much, everyone, and have a wonderful day.