Audit Report on the Compliance of New York City Emergency Management with Local Law 30 Regarding Access to City Services for Residents with Limited English Proficiency

May 21, 2019 | SZ18-129A

Table of Contents

Executive Summary

In 2017, the New York City Council enacted Local Law 30, effective July 1, 2017, which requires City agencies that provide direct public services or emergency services to have a language access plan that allows residents meaningful access to City services regardless of their proficiency in English.  These translation services must be provided in the top designated Citywide languages, which includes the top six limited English proficiency languages spoken by the population of New York City as determined by the Department of City Planning and the Mayor’s Office of Language Services Coordinator, and the top four limited English proficiency languages spoken by the population served or likely to be served by the agencies of the City of New York.

This audit focuses on whether New York City Emergency Management (NYCEM)[1] complied with Local Law 30.  NYCEM is responsible for the coordination of City-wide emergency planning and response for all types and scales of emergencies.  Its staff consists of over 200 professionals from diverse backgrounds and areas of expertise, including individuals assigned from other City agencies.

Audit Findings and Conclusion

We found that NYCEM generally complied with Local Law 30.  Our review of NYCEM’s Language Access Plans from 2008 through 2018 found that NYCEM has made continuous progress to provide meaningful language access to the agency’s services for City residents with Limited English Proficiency (LEP).  Its Language Access Plans described the steps that NYCEM has taken to provide its services to the LEP population.

Overall, we found that NYCEM provides these services during emergencies in 13 languages, including the top 10 New York City LEP languages.  Further, we found that through City-wide contracts with language vendors (Language Line Services, LLC and Geneva Worldwide, Inc. used in connection with 311, Voiance used for telephonic services, and ALanguage Bank used for translation services), NYCEM has the ability to provide documentation, translation, Communication Access Real Time Captioning, American Sign Language Video Remote Interpretation, and phone interpretation services in over 100 languages.  Appendices I and II contain details of the specific items we tested and the results of our tests.  Appendix III illustrates NYCEM’s efforts to ensure Local Law 30 compliance.

Agency Response

In its response, NYCEM agreed with the audit’s findings and recommendations. NYCEM stated, “[w]e agree with your findings and recommendation to continue to maintain compliance with Local Law 30. NYC Emergency Management strives to provide meaningful language access to people with limited English proficiency to our community preparedness programs and during emergencies.”

[1] NYCEM (formerly the Office of Emergency Management, or OEM) was rebranded as part of a comprehensive effort to increase the public’s awareness of its presence and role in the city.  This rebranding included phasing out the use of the OEM title, acronym, and logo.

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