Language Access Plan

The Illinois Department of Central Management Services (CMS) is committed to ensuring meaningful access to State employment, programs, and activities by limited English proficiency (LEP) persons. The Equal Employment Opportunity Office is responsible for creating and implementing the Language Access Plan (Plan). The Plan provides the framework for the provision of timely and reasonable language assistance to LEP persons who come in contact with CMS. The Plan will also help to ensure that CMS staff are aware of what to do when an individual with limited English proficiency needs assistance.

Individuals may file a complaint with the CMS Language Access Coordinator if they believe they have not received the CMS services set out in this Plan. The individual must file a written complaint within six months of the alleged denial.

To file a complaint with the CMS LAC specifically, submit the written complaint to:

CMS Language Access Coordinator
313 S. 6th Steet, 3rd Floor
Springfield, Illinois 62701
CMS.EEOOfficer@illinois.gov

I. INTRODUCTION: 

The Illinois Department of Central Management Services (CMS) is committed to ensuring that limited English proficient (LEP) persons have meaningful access to CMS employment, programs, services, and activities. This CMS Language Access Plan (Plan) provides the framework for offering timely, effective, and reasonable language assistance to LEP persons who interact with CMS free of charge. The Plan will also help to ensure CMS staff know how to proceed when an LEP individual is encountered and needs assistance.

This Plan is intended only to improve CMS’s operations and does not create any right or benefit, substantive or procedural, enforceable at law or in equity, by a party against CMS.

II. BACKGROUND:

The most common non-English primary languages spoken in Illinois are Spanish, Polish, and Chinese (including Mandarin and Cantonese).[1]

In 2023, the U.S. Census Bureau’s American Community Survey (ACS) estimated that 23% of Illinois’ population, aged 5 and over, spoke a language other than English at home.[2] Of those individuals, in the 18-64 age range, the ACS estimated that 41.1% of primary Spanish-speaking persons spoke English “less than very well.”  In this same age range, the ACS estimated that 32.2% of primary speakers of other Indo-European primary languages, 38.5% of speakers of Asian and Pacific Island primary languages, and 32.2% of speakers of other languages spoke English “less than very well.”  In the 65 and older age range, the estimates of those persons who spoke a non-English language and who spoke English “less than very well” were even higher: Spanish, 67.3%; other Indo-European languages, 53.5%; Asian and Pacific Island languages, 62.6%; other languages, 51.8%.  These numbers highlight the importance of ensuring that Illinois residents with limited English proficiency have meaningful access to State services.

III. SELF ASSESSMENT/DATA COLLECTION

Based on the requisite Four Factor Analysis, CMS has determined that it has limited interaction with the general public of the State of Illinois, including its population of LEP individuals.  The vast majority of interactions regarding CMS’s services, programs, and activities are geared towards other State agencies, boards, and commissions under the jurisdiction of the Governor.  Some of the personnel that engage in those interactions are bilingual in languages other than English, but few, if any, are LEP persons.  As a result, the frequency with which CMS comes into contact with LEP individuals is rare.  Exceptions are the Bureau of Personnel (BOP), the Bureau of Administrative Hearings (Hearings), the Bureau of Strategic Sourcing (BOSS), Diversity and Inclusion (D&I), and Benefits. The six primary languages of LEP persons who might have contact with those bureaus are: Spanish, Polish, Arabic, Hindu, Chinese, and Tagalog.

Based on the enactment of the Illinois Language Equity and Access Act (15 ILCS 56/1 et seq.), CMS will collect and monitor data for:

A. The number and percentage of LEP individuals who use CMS’s services listed by their primary languages other than English;

B.  Prepare a list of bilingual employees by title at CMS[3] including the languages other than English that the employees can speak, languages the bilingual employees are asked to speak by LEP persons, and whether the employees are certified as bilingual in those languages;

C. Data on interpretive and translation vendor services, including the number and type of language services requested, and the non-English languages requested; and

D. Data on the number of Language Access complaints filed and the status of complaints.

Collection and monitoring of data for encounters with LEP persons will be done based on the following:

Bilingual employees, non-bilingual employees, including but not limited to employees of BOP, Hearings, BOSS, D & I, and Benefits, and any staff who utilize the Illinois Document Translation Portal (IDTP) will prepare reports for requests for language assistance that they receive.  The reports will include, at a minimum, the date of the request, the agency services that generated a need for language assistance, the nature of the language services needed (Interpretation or Translation), the primary language of the LEP persons who require language assistance, the vendor services utilized, if any, as a result of the request, CMS documents, if any, related to the request, and the resolution of the request.

Reports will be submitted by the employees who have contact with LEP persons to their supervisors at the time of the language assistance request.  Supervisors shall submit copies of the reports to the Language Access Coordinator (LAC) periodically for review.  In turn, the LAC shall periodically report language assistance requests and information to the CMS Office of Legal Services, which supervises the LAC.

Staff who receive requests for payment for interpretation and/or translation language services provided by vendors will prepare reports for the dates of language services, the part of the agency that placed the orders for language assistance services, the services provided, and the primary languages of LEP persons who need language assistance and provide copies of them to the LAC on a monthly basis for review. In turn, the LAC shall periodically report language assistance vendor requests and information to the CMS Office of Legal Services, which supervises the LAC.

IV.  PLAN IMPLEMENTATION:

A. Plan Oversight

The primary duty of the CMS LAC is to ensure that individuals with limited English proficiency or those who solely speak languages other than English have equal access to employment, programs, services, and activities (collectively the “Aspects”) of CMS.  The LAC is primarily responsible for administering the CMS Language Access Program (Program), which includes this Plan, along with CMS’s language access policies and procedures (Policies and Procedures).  Overall, the LAC is crucial in ensuring that language barriers are eliminated and individuals with limited English proficiency have equal access to the various Aspects offered by CMS free of charge.

The LAC’s responsibilities include creating and overseeing the implementation of any Policies and Procedures, and modifying the Plan as needed.  BOP, the Deputy Directors of Hearings, BOSS, D & I, Benefits, and other designated CMS staff members will provide input, assessment, and assistance in carrying out the Plan and the Program.  At a minimum, the LAC will review the CMS Plan on an annual basis.  The LAC will consult with the relevant Bureaus and update the Plan, Policies, and Procedures on an as needed basis.  The CMS Office of Legal Services will supervise the LAC. 

The current LAC’s contact information is as follows:

Daniel C. Lanterman

CMS Legal Services

313 S. 6^th Street, 3rd Floor

Springfield, IL  62701

Primary email: CMS.LAC@Illinois.gov

Alternate email: Daniel.Lanterman@Illinois.gov

Direct Line Phone: (217) 725-5987

In the event of a change in the LAC, CMS Leadership will provide input, assessment, and assistance in finding or hiring a replacement LAC and provide onboarding training.  In the interim, the duties of the LAC will be assigned to the then current Deputy General Counsel of Personnel or their designee.

B. Identification of Funding and Procurement Issues

CMS currently provides language assistance services (interpretation and translation) through contracted providers.  For interpretation services, CMS uses Multilingual Connections for public facing meetings, presentations, and similar events for interactions with LEP persons and translations.  CMS uses Propio Language Services for other interactions with LEP persons.  If a specialized type of primary language service is not available under existing contracts, BOSS is available to help obtain the requested services. CMS also has access to the Illinois Document Translation Portal (Translation Portal), which is a web-based service provided by the Illinois Department of Innovation and Technology (DoIT).  The Translation Portal quickly converts documents written in English to one of the six (6) non-English languages identified by the Governor’s Office as being most spoken in Illinois (the top 6 languages).[4] Where appropriate, the Translation Portal can be used in conjunction with human translation services to provide meaningful access to LEP persons.  The LAC will work with BOSS and other appropriate CMS Bureaus to identify any funding and procurement issues and solutions. 

Based on past language access assistance usage, CMS forecasts it has enough funding to execute language access services as necessary.

Staff training is essential to the Program’s success. The Program’s training curriculum will include training on the Program’s Policies and Procedures, the importance of meaningful access, and cultural competence to LEP persons free of charge.

All senior leadership and public-facing employees within CMS will receive instructions on how to access and use interpretation or translation services effectively. They will also receive training on the documents and types of information already translated and where they can be found. Employees who interact directly with the public will receive additional training on how to work with in-person and telephonic interpreters, how to communicate effectively and respectfully with LEP individuals, how to record and track data about LEP persons’ language needs and preferred primary languages, and how to complete the annual reporting requirements. Bilingual employees will receive training on communication and interpretation skills, as well as ethics and confidentiality training. Current employees will receive initial training during the rollout period, followed by annual language access training. New employees will receive training as part of orientation followed by annual training.

C. Assessing the Need for Language Assistance

1. At the initial point of contact CMS staff will assess the need for language assistance and notify the LEP individual of the right to an interpreter free of charge. Staff members who have subsequent contact with the LEP individual will continue to assess the need for language assistance. Staff can determine whether a person needs language assistance and the person’s primary language in several ways:

a) Self-identification by the person or a companion;

b) Asking the person’s primary language if they have self-identified as needing, or appear to need, language assistance services;

c) Asking the person to indicate their primary language using an “I Speak” language identification card or poster; or

d) Asking a bilingual staff member (where available), or qualified telephonic or in- person interpreter, to verify the person’s primary language.

2. Staff will keep the following in mind when assessing the need for language assistance services:

a)   Staff should ask open-ended questions and avoid asking questions that allow for yes or no responses;

b)  The LEP person may speak more than one language but may not have the same level of proficiency in all of them. Staff should identify the primary language of the LEP person and work to provide language assistance in that language; and

c)   A deaf individual may also be limited English proficient and may not be proficient in American Sign Language. Staff should identify the primary language of the deaf individual and work to provide language assistance in that language.

D. Language Assistance Services to be Offered

CMS will provide written translation as well as interpretation where necessary to provide meaningful access to CMS’s programs, activities, and services.

1. Written Translation: Translation is the replacement of written text from one language into another. CMS will identify and translate vital documents to ensure LEP individuals have meaningful access to important written information. Vital written documents include, but are not limited to, consent and complaint forms; intake and application forms with the potential for important consequences; written notices of rights; notices of denials, losses, or decreases in benefits or services; notice of disciplinary action; signs; and notices advising LEP individuals of free of charge language assistance services. The vital documents CMS has identified to date are listed below in Section E. Where necessary to provide meaningful access, CMS will use its contracted service provider, or qualified bilingual staff (if available), to translate other documents. CMS will use these services in conjunction with the Translation Portal where appropriate.

2. Interpretation: An interpreter renders a message spoken in one language into one or more other languages. Interpretation can take place in-person, through a telephonic interpreter, or via internet or video interpreting.  An interpreter must be competent and have knowledge in both languages of the relevant terms or concepts particular to the program or activity the LEP person seeks, and the dialect and terminology used by the LEP person. Where necessary to provide meaningful access, CMS will use its contracted service provider to provide translation services. Where appropriate, CMS may also use bilingual staff (if available) to provide or obtain basic information to or from an LEP person.

E. Vital Documents Translation

1. CMS will translate vital documents as resources permit, taking into consideration the top 6 languages of Spanish, Polish, Arabic, Hindu, Chinese, and Tagalog based on the following factors:

a) The number and proportion of LEP persons likely to be served by CMS in its services, programs, and activities;

b) The frequency with which LEP individuals encounter CMS services, programs, or activities;

c) The nature and importance of the services, programs, or activities provided by CMS; and

d) The resources available to CMS and the costs of language assistance services.

2. Documents currently identified, or being considered, for translation include:

a) Bureau of Strategic Sourcing (BOSS) Documents

• Bid Documents/Instructions

• BidBuy Registration Documents

• Certifications and Disclosures

• Contract Language

• Pre-Bid Conference Documents/Information Shared

b)     Bureau of Personnel (BOP) Documents:

• Job Application

• Test Information Guide

• Veteran’s Preference Flyer

• Upward Mobility Program Information

• Disabled Worker’s Program Information

• Diversity Enrichment Program Information

• Reasonable Accommodation Request Form

• EEO Complaint Form

• Various Training Modules

c)     Bureau of Agency Services Documents:

• iBid Terms and Conditions for Purchases

• State Plan of Operations for General Services Administration Federal Surplus

d)     Bureau of Administrative Hearings Documents:

• Guide for Self-Represented Litigants (to be created)

e)     Bureau of Administrative Operations Documents:

• CMS Disability Access and Language Access Complaint Form

3. CMS will continue to review, identify, and translate vital documents to ensure the agency is taking reasonable steps to provide meaningful access to its programs, services, and activities for LEP persons at no cost to them.

F. Specific CMS Functions Requiring Language Assistance Services

1. Hearings. Hearings provides an impartial quasi-judicial forum where Illinoisans receive fair, prompt, and cost-effective resolution of disputes. Administrative hearing proceedings impact the rights, duties, and privileges of participants. Essential to a fair outcome is the opportunity for meaningful participation, including the removal of language access barriers. While Hearings has maintained a robust language access plan since its inception, including regular trainings for its administrative law judges, it will implement the new requirements of the Illinois Administrative Procedure Act 5 ILCS 100/10 et seq pursuant to Public Act 103-1056, effective July 1, 2025. In addition to the general provisions contained in this Plan, Hearings staff will take the steps listed in 2-6 to ensure LEP persons have meaningful access to the proceedings and that a complete and accurate hearing record is made and preserved.

2. Hearing Notice Enclosure. In compliance with Public Act 103-1056, beginning July 1, 2025, a multilingual enclosure accompanying each notice of hearing will be provided, at a minimum, in English, Arabic, Cantonese, Gujarati, Korean, Mandarin, Polish, Russian, Spanish, Tagalog, Urdu, Ukrainian, and Vietnamese. This notice will inform recipients and their representatives of their right to request interpretation services for participating in or understanding the hearing, as well as translation assistance for the contents of the notice.

3. Administrative Law Judge Inquiry. If no request for interpretive assistance is made but the administrative law judge (ALJ) reasonably believes that a self-represented litigant or witness is an LEP person, the ALJ will inquire if the individual needs interpretive assistance to participate in or understand the hearing. The ALJ’s conclusion regarding the need for interpretive assistance will be stated in the record.

4. Interpreter Oath. The presiding ALJ will ensure the interpreter takes an oath to discharge properly the interpreter function. Interpreters must swear or affirm that they: (1) will make a true interpretation, from the English language, in an understandable manner to the LEP person for whom the interpreter has been appointed; (2) will repeat the statements of the LEP person, in the English language, to the best of the interpreter's ability; (3) have not had any involvement in the issues of the case before the hearing; and (4) will not disclose privileged or confidential communications to any person.

5. Addressing Interpreter Error. To ensure the most accurate possible interpretation on the record, the ALJ will accept the correction of errors when offered by the interpreter. Hearings staff will develop a procedure to address any disputes about interpretation accuracy that are not resolved through agreement.

6. Waiver. To waive any of the provisions relating to language access services under Public Act 103-1056, the parties must provide a signed written stipulation in both English and the preferred language of the party in need of language assistance. This written stipulation waiving the language access service may be withdrawn by the LEP person at any time, by oral declaration at hearing, or in a written declaration.

7. Translation of Informational Materials. Hearings staff will develop general informational materials explaining the administrative hearing process, which will be translated into multiple languages to ensure broad public understanding and meaningful access by LEP persons.

8. Other Bureaus Other Bureaus within CMS may have specific language assistance service needs depending on the services they provide. For all CMS Bureaus, translators and interpreters must be qualified or independently certified. Bilingual staff may be called upon to provide basic information to an LEP person such as instructions for completing forms, meeting dates, submission deadlines, and contact information.

G. Notice of Language Assistance Services

CMS will make information regarding the Plan available to all employees and members of the public. CMS will post notices regarding the availability of language assistance services in public areas of CMS facilities and on CMS webpages. CMS will include a tagline about the availability of language assistance services free of charge on printed and electronic communications related to CMS programs, services, and activities. CMS will include a mailing insert with all important notices or letters sent to members of the public. This insert will contain information in the top 6 languages informing LEP individuals of the availability of free language assistance services.

For administrative hearings specifically, beginning July 1, 2025, an enclosure accompanying each notice of hearing will go beyond the top 6 languages as indicated above under CMS Specific Functions Section F (1).  In addition, CMS will source “I Speak” materials to facilitate identification of the primary languages spoken by LEP persons who use CMS services and ensure that these materials are placed in public areas of CMS facilities. CMS will also include non-English instructions on its public-facing telephone menus.

H. Outreach to LEP Communities and Other Stakeholders

CMS D&I is currently in charge of planning and implementing the requirements of the Hispanic Employment Plan 20 ILCS 405/120, the African American Employment Plan 20 ILCS 30/1 et seq, the Asian American Employment Plan 20 ILCS 405/120, the Native American Employment Plan 20 ILCS 60/1 et seq. and the Bilingual Needs and Pay Employment Plan 20 ILCS 415/8a.2 & 20 ILCS 415/9(6).   The LAC will collaborate with the Deputy Director for D&I and with BOP to plan, leverage, and implement outreach strategies to LEP communities and organizations to help increase the number of bilingual CMS staff and connect LEP persons to the Program.

Currently, D & I’s outreach is mainly geared toward forming professional ties with community groups, professional groups, and groups that advocate for minorities.  Some members of those various groups are LEP persons.  However, D & I staff primarily interacts with the staff of the various community, professional, and minority advocacy groups.  Those staff members are typically proficient in English as their primary language or bilingual rather than LEP members. 

Special emphasis will always be placed on the fact that all language assistance for LEP persons is free of charge. LEP considerations will also be incorporated into agency-wide marketing strategies.

I. Language Access Complaint Procedure

Individuals may file a complaint with the LAC free of charge if they believe they have not received meaningful access to a CMS service, program, or activity. The individual must file a written complaint within six (6) months of the alleged denial. To file a complaint with the LAC, the individual must complete and submit the current CMS Disability Access and Language Access Complaint Form or any future updated uniform complaint forms to:

CMS Language Access Coordinator

313 South 6th Street,

3rd Floor

Springfield, Illinois 62701

The CMS Language Access Coordinator will review the complaint and discuss it with the Bureau referenced within the complaint to ascertain what, if any, remedial measures need to be taken.  Additionally, the LAC and the relevant Bureau will determine whether additional training should be implemented or if any amendments need to be made to the Plan.  Other CMS Bureaus and/or CMS Senior and Executive Leadership will be consulted as needed.

In addition, if the individual believes that their complaint is not being resolved in a timely manner and/or CMS’s resolution is inadequate, the individual can elevate the complaint free of charge to:

Illinois Governor’s Office of New Americans (ONA) GOV.NewAmericans@illinois.gov

ONA may engage in an informal process including mediation, conference, and conciliation to resolve the Complaint.

J. Monitoring and Updating the Plan, Policies, and Procedures

The LAC will work with CMS’ language assistance service provider to obtain periodic reports showing how often CMS staff use the contracted language assistance services and the specific primary languages and services requested. Additionally, the LAC will consult with the relevant Bureaus to draft procedures for CMS staff who interact directly with the general public to document and track non-English language interactions.

The LAC will also work with CMS’ Deputy Director for D&I and with BOP to create and distribute a voluntary survey of CMS bilingual staff, including their level of proficiency in reading, writing, and speaking non-English languages; their level of comfort using these skills as part of their employment with CMS and their willingness to undergo communication, interpretation, ethics, and confidentiality training as described in this Plan.

Additionally, the LAC will develop procedures for surveying relevant CMS staff members and LEP individuals about their use of language assistance services, suggestions for improvement, and whether the services provided offer meaningful access to the LEP communities CMS serves. The LAC will also consult periodically with other State agencies and entities to ensure continual improvement in CMS’ provision of language assistance services.

Using these and other data sources, the LAC will review the Program annually and assess:

1. The LEP demographics served by the relevant Bureaus.

2. The language needs of the LEP persons who use the language assistance services provided by CMS.

3. CMS’ responses to complaints or suggestions from LEP individuals, community members, and employees regarding the language assistance services provided.

4. The effectiveness of the Policies and Procedures and the language assistance resources currently in place; and 

5. Gather data and metrics required by the Illinois Language Equity and Access Act to be used to monitor Plan performance and provide training.

K. Five-Year Action Plan

CMS will address the action items outlined below over four phases spanning five years:

Phase 0 (Year 0)

• Continue to provide Language Access services as needed in an accurate, timely, and effective manner for LEP persons free of charge
• Adopt a uniform certification process for Bilingual employees to be used by all agencies, boards, and commissions under the jurisdiction of the Governor
• Consider revising the CMS website to place language assistance information in a more prominent and noticeable place for LEP persons 
• Create forms for monitoring and collecting data for all of CMS’s encounters with LEP persons across the agency
• Provide training for the monitoring forms for encounters with LEP persons
• Prepare to submit Language Access reports for FY26 by December 31, 2026

Phase I (Year 1)

• Reassess its Four-Factor analysis as needed based on the result of its monitoring and data collection for encounters with LEP persons
• Continue to provide training for staff that has encounters with LEP persons
• Review and revise data monitoring forms as needed
• Assess the implementation and effectiveness of its previous Goals and modify as needed

Phase II (Years 2 and 3)

• Reassess its Four-Factor analysis as needed based on the result of its monitoring and data collection for encounters with LEP persons
• Revise and expand goals based on updated data collected during Years 1, 2, and 3
• Identify areas of opportunity for adjustment in methods of delivery of LEP services based on experiences gained during Phase I and II

Phase III (Years 4 and 5)

• Reassess its Four-Factor analysis as needed based on the result of its monitoring and data collection for encounters with LEP persons
• Assess the implementation and effectiveness of its previous Goals and modify as needed.
• Revise and expand goals based on updated data collected during Phases I-III
• Identify areas of opportunity for adjustment in methods of delivery of LEP services based on experiences gained during Phases I-III

Updated November 25, 2025