Comment Request: Servicing SNAP Applicants and Participants with Limited English Proficiency

Summary

As federally assisted programs, both SNAP and Nutrition Assistance Program (NAP) are required to comply with Title VI of the Civil Rights Act of 1964 (Title VI) and its implementing regulations for the USDA at 7 CFR 15. (U.S. Department of Justice Civil Rights Division n.d.). Title VI prohibits entities that receive federal financial assistance from discriminating against or otherwise excluding individuals on the basis of race, color, or national origin. In order to avoid discrimination against LEP persons on the ground of national origin, administrators of federal financial assistance programs must take reasonable steps to ensure that LEP persons receive the language assistance necessary to afford them meaningful access to SNAP or NAP as applicable, free of charge. LEP individuals are defined as those who do not speak English as their primary language and have a limited ability to read, speak, write, or understand English (USDA 2014, p. 70775). Meaningful access requires that state agencies provide language assistance services that allow equal participation in and access to the benefits of a given program. To support meaningful access, language assistance must be provided at a time and place that avoids the effective denial of the service, benefit, or right at issue or the imposition of an undue burden on or delay in important rights, benefits, or services to the LEP person (USDA 2014, p. 70779-70780).

The LEP study will provide FNS with actionable insights about how states and territories operate language access policies and requirements. The study will gather detailed data from all 53 state SNAP agencies via a web-based survey, the three territories that operate NAP via in-depth interviews, and will conduct case studies in four states. The study will provide FNS with a comprehensive summary of findings on policies and practices related to LEP access. It will increase FNS' understanding of SNAP LEP access policies and practices across the nation, including how states make decisions about these policies and practices, how they train staff on them, and their perceptions of federal regulations. The findings from the study will help inform policymakers efforts to provide more meaningful access to SNAP and NAP.