Social Security

Name of Project: Social Security Administration's Plan for Providing Access to Benefits and Services for Persons with Limited English Proficiency (LEP)

Introduction: Section 2 of Executive Order 13166 requires Federal agencies to develop and implement a plan for improving LEP individuals’ access to services and participation in federally conducted programs and activities. The Department of Justice (DOJ) requested that each Agency submit its plan to improve the language accessibility of its federally conducted programs and activities and to take steps to implement the plan. Social Security submitted its original LEP plan to DOJ on December 19, 2000. We updated our LEP plan in February 2003, September 2004, July 2008, and February 2010. According to DOJ, each Agency and each recipient of Federal financial assistance must take reasonable steps to provide meaningful access to LEP individuals using a "4-factor" analysis. Factors that we consider when determining what constitute reasonable steps to ensure meaningful access to LEP individuals are the:

• number or proportion of LEP persons in the eligible service population;
• frequency with which LEP individuals come into contact with the program;
• importance of the service provided by the program; and
• resources available to the recipient.

We will ensure that these factors are considered when developing new programs and projects, particularly through our delivery of electronic services.

Background: Social Security's efforts to improve services to increasing numbers of LEP individuals predate Executive Order 13166 (issued in August 2000). In February 1995, Social Security chartered the LEP inter-component workgroup, which meets on a regular basis and is responsible for Social Security’s LEP activities. In September 1995, the Commissioner approved Social Security’s LEP policy, principles, and implementation plan. Since then, we have been proactive in the implementation of a comprehensive plan for the provision of increased access and services to LEP individuals.

Vision Statement: Social Security strives to provide effective, efficient, and equitable service to the public.  We aim to provide members of the public with access to our services, regardless of their ability to speak, read, or write English.

Social Security continuously seeks to improve and expand service delivery options available to LEP individuals, enabling them to communicate effectively with Social Security in person, over the phone, in writing, or through electronic media and services. This vision is aligned with key goals from our strategic plan, as follows:  

• Eliminate our hearings backlog and prevent its recurrence;
• Improve the speed and quality of our disability process;
• Improve our retiree and other core services; and
• Preserve the public’s trust in our programs.

Summary of Social Security’s LEP Policy: To make the public, as well as SSA’s public-contact employees, aware of our LEP service delivery guidelines, we have distributed our LEP policy and procedures.  Our policy ensures that individuals have access to our programs and services, regardless of their ability to communicate in English.  Social Security does not require individuals who need language assistance to provide their own interpreters; rather, we provide an interpreter free of charge, to any individual requesting language assistance or, when it is evident that such assistance is necessary to ensure that the individual is not disadvantaged.

Our LEP policy principles, approved in 1995, include the following elements:

A. Resource Allocation: Social Security will consider the needs of LEP individuals in all of our policies and long-range business and strategic plans. The service needs of LEP individuals are carefully considered in our resource allocation, and we adopt service delivery initiatives that we can fully fund.  As we deliver more services electronically, we will continue to assess the allocation of resources for LEP services

B. Service Delivery: LEP individuals access to Social Security's services through our network of approximately 1,300 field offices (FOs), 140 hearing offices (HOs), and the national 800 telephone number.  Field offices develop strategies tailored to the needs of their communities to provide efficient and effective service.  Through a variety of outreach activities, field offices also create and maintain cordial working relationships with different LEP communities.

C. Bilingual/Bicultural Staffing: The most effective method for providing quality service to LEP individuals is through bilingual/bicultural or multilingual public-contact employees.   We identify bilingual/bicultural hiring needs through the continual assessment of changing language and cultural demographics.   

D. Qualified Interpreter Services: Social Security uses either qualified office based interpreters or telephone interpreters available through a national contract.  If the LEP individual prefers to use his/her own interpreter, such as a family member, friend, or third party, Social Security will determine whether the interpreter meets our requirements.  We generally will not permit a child under age 18 to serve as an interpreter (due to the nature and complexities of our business processes).

E. Public Information: Social Security recognizes the value of public information to educate, improve access to our services, address LEP concerns, promote program integrity, and build public confidence in the programs we administer.  Social Security produces public information materials in 15 languages (other than English) at http://www.socialsecurity.gov/multilanguage/.  Materials are accessible through this Multilanguage Gateway.  We utilize national and local ethnic media, as well as advocacy groups and community based organizations to disseminate this information to LEP individuals.

F. Written Communications: In order to facilitate access to our programs and to improve administrative effectiveness, Social Security nationally produces written communications, such as public information materials, notices, and form letters, using the following criteria:

• number of LEP beneficiaries/applicants;
• number of impacted field offices;
• literacy level in the non-English language;
• anticipated demographic growth; and
• cost-effectiveness.

G. Listening to LEP Individuals: Social Security does periodic focus group testing, and we have an online comment and suggestion system in place to respond to the public’s concerns and comments.  We understand that better communication with LEP individuals:

• increases public understanding of our programs by providing information to individuals in a language they read, speak, and understand;
• increases an individual’s satisfaction when we provide service by bilingual/bicultural staff;
• improves program integrity, and
• streamlines contacts by identifying the language preference at the initial contact with Social Security, thereby reducing the need for re-contacts.

H. Outreach to LEP Individuals: We promote Social Security’s language access servicesto LEP individuals through our national network of over 150 public affairs specialists (including bilingual public affairs specialist), bilingual/bicultural staff in Social Security field offices, and the Office of Communications’ liaison activities with national and community-based organizations. 

I. Technology: When evaluating existing and emerging technologies, we consider the needs of LEP individuals, the resources available to meet those needs, and the level of impact the technology will have on the LEP community. 

J. Training: Social Security provides training opportunities in cultural diversity for all employees in order to provide better service to LEP individuals.  We also provide training to enhance the language skills of our bilingual employees.

K. Monitoring Our Services: Social Security collects and tracks our LEP data on an ongoing basis at the national, regional, and local levels to determine the needs of the community and to allocate resources accordingly. We monitor our LEP policies and practices to ensure that they continue to be effective. To determine shifts in LEP demands, we also reevaluate the language groups that are most represented among the LEP population.

Social Security is committed to providing equal access to services for LEP individuals. We recognize the rich diversity of the American public and are sensitive to the special needs of the LEP population. Generally, LEP individuals require more personalized service, such as interpreter services for face-to-face or telephone interviews and assistance in translating documents across program lines. We strive to offer this level of customization for LEP individuals.

Factor 1: Demography - Number or Proportion of LEP Individuals

• know the preferred languages of the individuals we serve;
• know where the language demands are located; and
• make informed staffing and resource allocation decisions.

 Has your organization developed a demographic profile of the population served?

Yes.  As early as 1996, Social Security began collecting and projecting language preferences for 26 languages.  In June 2004, we expanded the number of language preference options for which we collect preference data from 27 to 90.  Having the ability to collect additional language preference data on the populations we serve allows us to strategically place bilingual staff.  This has enhanced our ability to determine where language demands are located and thus make more strategic staffing and resource allocation decisions.

In fiscal year (FY) 2008, we projected that approximately 5.9 percent or 643,282 claimants out of 10,851,981 preferred to be interviewed in a language other than English. 

Table 1 depicts the top five language preferences by initial claims category, and table 2 shows the top five language preferences by other Social Security services for FY 2008. 

Table 1: FY 2008 Top Five Language Preferences Among Initial Claims
Title II – Old Age, Survivors, and Disability Insurance Benefits (This includes the Virgin Islands and Puerto Rico)
Retirement & Survivor		Disability Insurance
Spanish	139,029	Spanish	94,753
Chinese (Includes Cantonese & Mandarin)	10,511	Vietnamese	2,428
Vietnamese	6,634	Chinese	1,669
Korean	4,346	Russian	964
Japanese	3,860	Korean	811
Title XVI – Supplemental Security Income Benefits for the Aged, Blind, and Disabled (This does not include the Virgin Islands and Puerto Rico)
Aged		Blind & Disabled
Spanish	60,369	Spanish	105,072
Chinese	9,782	Vietnamese	3,034
Vietnamese	3,918	Chinese	2,545
Korean	2,985	Russian	1,683
Tagalog	strong>2,147	Armenian	1,581

Table 2: FY 2008 Top Five Language Preferences for Other Social Security Services
Title II Post Entitlement (The term, post entitlement, is used to describe all events and updates associated with a beneficiary’s claim after the beneficiary has been determined to be entitled and receiving benefits.  This includes such actions as a change in address or telephone number, a report of earnings, or an update for direct deposit.  The data displayed includes the Virgin Islands and Puerto Rico)		Title XVI Redeterminations (This does not include the Virgin Islands and Puerto Rico)
Spanish	49,737	Spanish	84,891
Korean	1,903	Chinese	10,496
Chinese	417	Vietnamese	8,787
Tagalog	285	Russian	4,971
Armenian	212	Korean	3,340

Factor 2:  Frequency of Contact with the Program
Does your organization collect/record primary language data for individuals who participate in your programs?

Yes.  As noted above in Factor 1, we collect language preference information on individuals who apply for:

• Retirement, Survivors and Disability Insurance; and
• Supplemental Security Income.

LEP individuals contact Social Security on a daily basis in person, by mail, phone, or Internet, to apply for benefits, request other services, or ask questions about the programs we administer.  The highest percentage of non-English language demand is in Supplemental Security Income (SSI) Aged applications.  In FY 2008, about 31% of the SSI Aged applicants preferred to have their interview in a language other than English.

Table 3 indicates the overall volume of initial claims that Social Security processed in FY 2008, and the number of beneficiaries who preferred language other than English.

Table 3: FY 2008 Overall Volume and Preferred Language Other than English by Programs
Social Security Programs	Overall Volume	Number of Beneficiaries who prefer language other than English
Title II Retirement and Survivors Insurance	4,650,797	188,596
Title II Disability Insurance	2,693,501	112,180
Title XVI SSI Aged	309,209	96,894
Title XVI SSI Blind and Disabled	2,365,925	129,228

Factor 3: Nature and Importance of the Program
Social Security provides social insurance protection for more than 162 million workers and their families.  In 1937, the Social Security Act established a program to help protect aged Americans against the loss of income due to retirement.  In 1939, Congress added the protection for survivors of deceased workers, creating the Old Age and Survivors Insurance (OASI) program.  Congress expanded Social Security again in 1956 to include the Disability Insurance (DI) program.  Social Security’s responsibilities also include administration of the Supplemental Security Income (SSI) program (added in 1972), and the Special Benefits for Certain World War II Veterans (Title VIII added in 1999).  The Medicare Prescription Drug Improvement and Modernization Act of 2003 expanded Social Security’s responsibilities to inform Medicare beneficiaries about the extra help program, assist them in filing applications, and make eligibility decisions on those claims. 

Though Social Security administers all of the programs listed above, it is important to highlight the SSI program given its high volume of non-English language demand.  Through this program, we pay monthly benefits to people with limited income and resources who are age 65 or older, blind, or disabled.  Blind or disabled children can also receive SSI.  In most states, filing for and receiving SSI results in eligibility for Medicaid (medical assistance), and in most states, applications for food assistance are provided to individuals applying for or receiving SSI. Thus, for LEP individuals who are eligible for SSI, Social Security plays a critical role in helping provide monthly benefit payments and linkages to medical and food assistance services.

Factor 4: Resources The Social Security Administration operates a centralized headquarters location and a decentralized network of 10 regional offices, and the regional offices oversee approximately 1,300 field offices, 7 program service centers, 35 teleservice centers, 7 Social Security card centers. In addition, there are 146 hearing offices and 2 national hearing centers under 10 regional offices of Disability Adjudication and Review (ODAR). As an agency, Social Security is uniquely positioned (through its network of public-contact offices) to assist LEP populations. We direct resources to LEP activities in the form of:

• hiring bilingual staff where bilingual skills are needed;
• providing for contracted third-party interpreters at no charge to the individual;
• providing for contract translations and typesetting services to produce non-English language materials, and
• training SSA's network of public-contact employees. Hiring initiatives have focused on achieving the right mix of employee language skills to serve LEP individuals.

As of January 2010, we identified 9,950 Social Security bilingual and multilingual employees in the Office of Operations who can speak one or more languages, representing 133 different languages and dialects (Source: Office of Operations/Office of Public Service and Operations Support ). Since FY 2003, approximately 7.44 percent (1,882 out of 25,291) of all new hires, including temporary employees were bilingual or multilingual (Source: Office of Human Resources/Office of Civil Rights and Equal Opportunity).

When bilingual or multilingual employees are not available, we provide third-party interpreters at no cost to the requesting individual.

Table 4 shows annual expenditures for translation and interpreter services for Social Security’s field offices and hearing office (Source: Office of Operations/Office of Public Service and Operations Support and Office of Disability Adjudication and Review).

Table 4: SSA Expenditures for Translation & Interpreter Services
Fiscal Year	Field Offices	Hearing Offices
2006	$562,550	$2,155,808
2007	$477,780	$2,328,986
2008	$522,364	$2,137,404
2009	$504,866	$2,390,000

Since October 2002, Social Security has also provided Telephone Interpreter Services (TIS), and this is available for use by Social Security’s public-contact employees.  In FY 2009, the actual expenditure for the TIS was $2,491,100.  In FY 2009, we provided the total of 236,560 calls in 127 different languages and dialects. 

Table 5 shows the most frequently requested languages(Source: Office of Operations/Office of Public Service and Operations Support ).

Table 5: FY 2009 Telephone Interpreter Services;Top Five Requested Languages
Language	Number of Calls
Spanish	128,271
Chinese (Cantonese & Mandarin)	23,945
Vietnamese	15,023
Russian	9,829
Korean	9,349

As the agency’s lead component for LEP responsibilities, the Office of External Affairs (OEA) in the Office of Communications works to ensure that LEP individuals have access to our services, regardless of their ability to communicate with us in English.  OEA leads Social Security’s LEP Intra-agency Workgroup, which is comprised of representatives from various SSA offices. 

Social Security’s public-contact employees and public affairs specialists conduct outreach activities to LEP individuals at the national, regional, and local level.  Some highlighted activities are:

• Social Security is currently developing a Spanish version of our online “Retirement Estimator”
• In November 2009, Social Security revised its Discrimination Complaint Form (SSA-437) to include a new basis, “Limited ability to speak English”
• OEA conducted an LEP breakout session at Social Security’s National Public Affairs Training Conference in June 2009
• Conducted a LEP workshop at the Hmong National conference in April 2009
• Presented Social Security’s ongoing services to LEP individuals at the National Council of Asian Pacific Americans monthly meeting on April 7, 2009
• Conducted a workshop titled,  “Innovative Online Resources for Agencies Serving LEP Populations” at the 2008 Federal Inter-agency Working Group on LEP National Conference, held at the NIH Conference Center in Bethesda, MD
• Produced a video-on-demand refresher training session for SSA public-contact employees in May 2008
• Updated operating instructions for our Translation and Priority Workload Unit in April 2008
• Participated as an exhibitor and presenter at the 2007 Federal Interagency Working Group on LEP National Conference, held at the National Institute of Health Conference Center in Bethesda, MD

Social Security provides written materials in languages other than English through our Multilanguage Gateway at http://www.socialsecurity.gov/multilanguage/.  Our redesigned “En Español” website http://www.socialsecurity.gov/espanol/ contains over 100 Spanish public information materials.

On a regular basis, we update the following public information materials in other languages:    

• Retirement and Survivors Benefit Fact-Sheet: Arabic, Armenian, Chinese, French, Greek, Haitian Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese
• Disability Benefits Fact-Sheet: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog and Vietnamese
• Supplemental Security Income Rights and Responsibilities Handout: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese
• Special Benefits for WWII Veterans Fact-Sheet: Tagalog
• Representative Payee Dedicated Accounts Fact-Sheet: Armenian, Chinese, Hmong, Korean, Laotian, Tagalog, Russian and Vietnamese
• A “Snapshot” of Social Security Programs: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog and Vietnamese
• Getting Extra Help with Medicare Prescription Drug Plan Costs, Income and Resource Limits: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese
• Review of Your Eligibility For Extra Help With Medicare Prescription Drug Plan Costs: Some Things You Should Know: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese
• What You Need to Complete the Application for Extra Help with Medicare Prescription Drug Plan Costs: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese
• Help Someone Save an Average of $3,900 on Prescription Drug Costs: Arabic, Armenian, Chinese, Farsi, French, Greek, Haitian-Creole, Italian, Korean, Polish, Portuguese, Russian, Spanish, Tagalog, and Vietnamese
• Social Security Terminology Glossary: English-Spanish; English-Haitian Creole; English-Korean; English-Chinese and English-Vietnamese
• Translated 58 publications into Spanish, including Monthly Information Packages and Understanding Supplemental Security Income publication

For Social Security employees, we developed an “Interviewing Guide” and training materials in Spanish, Vietnamese, Navaho, Polish, Chinese, Russian, Filipino languages, German, French, Haitian-Creole, Italian, Korean, Arabic and Portuguese.  We also translated the “Interpreter Service Policy” poster in 19 different languages, and have them displayed in our field offices.