Language Access Plan for Limited English Proficient Individuals
Para solicitar esta información en español, envíe una solicitud a través de hello@flagstoneinitiative.org.
To request this information in another language, please submit a request to hello@flagstoneinitiative.org.
The Flagstone Initiative is a 501(c)(3) nonprofit organization dedicated to upstream prevention of eviction and homelessness through a combination of financial stability programs, primarily through two no-fee, no-interest, no-penalty programs: Rent Splitting and Rent Loans.
These programs are provided in partnership with rental housing providers and nonprofits dedicated to improving housing stability. We communicate with individual renters through these partnerships, primarily using email and flyers.
The Flagstone Initiative believes that all consumers, regardless of the language they speak, should have meaningful access to information about our programs. The Flagstone Initiative is committed to providing meaningful access to information and services for LEP individuals, consistent with Title VI of the Civil Rights Act of 1964 and Executive Order 13166. The following is the Flagstone Initiative’s policy regarding services for LEP individuals.
It is the policy of the Flagstone Initiative not to discriminate against any person who is Limited English Proficient (LEP). In accordance with Title VI of the Civil Rights Act of 1964 and Executive Order 13166, the Flagstone Initiative will take all reasonable steps to provide LEP persons meaningful access to program information upon request.
The purpose of this policy is to establish effective guidelines, consistent with Title VI of the Civil Rights Act of 1964 and Executive Order 13166, for Flagstone Initiative personnel to follow when providing services to, or interacting with, LEP individuals. Following this policy is essential to the success of the Flagstone Initiative’s mission in ensuring reasonable access to LEP individuals.
LEP persons may request relevant materials from the Flagstone Initiative via our website. The Flagstone Initiative provides language assistance, on an as-available basis, using contractual services provided by a third-party vendor.
Upon request and within reasonable time restraints, the Flagstone Initiative will provide translations of our information into Spanish or other languages. The Flagstone Initiative will decide how to allocate its resources for translation services based on relevance, time or cost restraints.
Language Access Needs Assessment
In accordance with our commitment to ensuring meaningful access to LEP individuals, we ask our partners about the communities they serve, including the percentage of those who might require translated materials or translation services. In communities where there is a significant LEP population, we provide translated communications. To date the translations provided have been in Spanish.
To further determine the relevance of translated materials for LEP individuals, we also track the percentage of survey respondents who choose the Spanish translation for their responses. Since January of 2024, this has been 2% of respondents, with the highest percentage at a given property being 8%.
Potential areas of interaction with LEP individuals include:
- Monthly Email communications
- One-time Flyer communications
- Rent Loan information webpage and application
- Resident Survey
We have identified the following documents as essential for LEP individuals to access vital information and services:
- Monthly Rent Splitting communications
- Rent Loan information webpage and application
- Legal notices
Our current language access practices include:
- In communities where we are aware of a notable Spanish-speaking population, we provide Spanish language versions of Rent Splitting and Rent Loan outreach emails.
- Including a note in Spanish to let Spanish speakers know how to request Spanish materials for all listed contact points and vital documents. [e.g., “Para solicitar esta información en español, envíe una solicitud a través de hello@flagstoneinitiative.org.” or “Hablantes de español, para obtener ayuda con esta solicitud, envíe un correo electrónico a hello@flagstoneinitiative.org.” (as appropriate)]
- Spanish Speakers can toggle the Resident Survey into Spanish themselves.
Language Assistance Services
The Flagstone initiative does not use real-time, spoken communication as a way to interact with those we serve. All our materials are available exclusively in online formats, and we do not have a phone number where clients can call in to speak with a representative.
Since we currently handle all client communications through email, we are not in need of a bilingual staff-member or third party vendor for situations like the one described above. If we do begin to offer real-time communication options, we will hire a staff member who is capable of real-time translations.
The Flagstone Initiative hires contractual services provided by a third-party vendor to translate our two most complex communications into Spanish (Rent Splitting monthly communications, Resident Survey).
For our frequent but relatively simple communications, we have added multiple invitations for clients to reach out to us to receive a copy of the material in Spanish or other languages (Rent Loan webpage, Rent Loan application). [e.g., “Para solicitar esta información en español, envíe una solicitud a través de
hello@flagstoneinitiative.org.” or “Hablantes de español, para obtener ayuda con esta solicitud, envíe un correo electrónico a
hello@flagstoneinitiative.org.” (as appropriate)]
We use online translation services ourselves to translate our infrequent materials into Spanish, and have bilingual-staff members of our housing partners proofread these materials to ensure our translations are quality and accurate (One-time flyer communications). If residents need translations to languages other than Spanish, we use the same process. For individualized communications, we use commercially available translation services [e.g., Google Translate] to validate our staff’s basic Spanish language skills.
Our customer service staff has basic Spanish language skills, and we recognize that having a bilingual member of our own staff would be helpful in further building trust with our clients. We work closely with the bilingual staff members of our housing partners to ensure residents have an in-person contact to help with translations if they need it. Often, these staff members are a part of specific resident services teams that focus on building resident trust with the property, and helping residents access resources like ours.
The Flagstone Initiative will disseminate Spanish-language versions of all information via email when it is requested. Our only non-email or web-based communication (the one-time flyer) is available on-site at the clients property in both English and Spanish.
Responsible Staff
The Flagstone Initiative’s leadership provides guidance and information to staff regarding Flagstone’s responsibility to LEP individuals through an annual memorandum outlining the Flagstone Initiative’s policy and the resources available. Flagstone’s LEP Coordinator will track the number of language requests received and the languages requested.
All staff at The Flagstone Initiative have read and understand Flagstone’s language access policy and procedures, and this is included in our employee policies as part of our ongoing efforts to ensure equitable, inclusive, and responsive financial services.
Monitoring and Evaluation
Our language access requests are monitored in multiple ways, to ensure we have an accurate sense of the need we are responding to.
- We work with our housing partners to get a sense of their resident population that is LEP, and what languages outside of English are most commonly spoken at the property (So far, Spanish has been the only language primarily spoken outside of English)
- The Resident Survey counts the number of individuals who choose to toggle and take the survey to Spanish.
- We track the number of email requests we receive for language assistance with our materials.
We gauge the effectiveness of our LAP through:
- The success of the interactions we have with the clients who request language assistance. So far, we have not received a request that we were unable to deliver directly to an LEP client.
- We gather feedback on our communications from bilingual property staff that helps us ensure quality materials are available to their LES residents. They have helped us improve our translations, and effectively communicate with their residents.
We do not currently have a formal annual review process to assess our LAP effectiveness, but we make periodic reviews and adjustments of our material so that it best relays the information relevant to our services.
We do not currently have a formal reporting process that we share with stakeholders, but we keep all our housing partners informed that all the materials available to residents at their property can be made available in other languages.
Resource Allocation
The Flagstone team does not currently have a full time bilingual staff member, or resources dedicated specifically towards language accessibility, since we are a small team and serve few clients who need these services. In the event that the LEP population we serve grew, we would allocate a proportional budget towards the amount of resources that are dedicated to serving this population's needs.
We work with our housing partners to get a sense of the amount of their resident population that is LEP, and what languages outside of English are most commonly spoken at the property. Based on the information that our partners have provided to date, we have prioritized Spanish translations. All materials we offer to residents are accessible in Spanish, either directly through the communication itself, or by contacting the Flagstone team.
Public Notice
Our Language Access Plan is easily and publicly available on our website. We do make use of public spaces or hold in-person outreach events, so we are not able to advertise our LAP in that way.
Non-discrimination and Civil Rights Information
In accordance with federal laws and U.S. Department of the Treasury policy, this organization is prohibited from discriminating on the basis of race, color, national origin, sex, age, or disability. To file a complaint of discrimination, write to: U.S. Department of the Treasury, Director, Office of Civil Rights and Equal Employment Opportunity 1500 Pennsylvania Avenue, N.W., Washington, DC 20220; or send an e-mail to: crcomplaints@treasury.gov.
Contact Information
The Flagstone Initiative maintains a designated LEP Coordinator. This is currently Keith Pelczarski, one of our co-founders. Any inquiries related to this Language Access Plan can be directed to hello@flagstoneinitiative.org.
Para solicitar esta información en español, envíe una solicitud a través de
hello@flagstoneinitiative.org.
To request this information in another language, please submit a request to hello@flagstoneinitiative.org.
