Audit Report on the Office of the New York City Public Advocate’s Provision of Language Access Services

October 10, 2025 | SZ25-075A

Table of Contents

Audit Impact

Summary of Findings

The audit found that the Office of the Public Advocate (“PAO”) generally complies with the website translation and in-person and telephonic interpretation standards prescribed by relevant laws, standards, and guidelines, with some exceptions noted below. The language access services provided by PAO generally meet the needs of the Non-English Language Preference (NELP) population as intended, and the NELP population generally has the same access to government services as the English-speaking population.

However, the audit found that PAO was not fully compliant with certain aspects of Local Law 30. Specifically, PAO’s website did not indicate whether the agency provides free language access services, did not generally allow for translation of PAO’s published reports and other documents into the City’s top 10 NELP languages, and did not list the name and title of its Language Access Coordinator.[1] Also, PAO did not have a Language Access Implementation Plan (LAIP), as required.

During the audit and at the exit conference held on August 5, 2025, PAO officials provided auditors with documentation showing that they had begun implementing the audit’s recommendations. Auditors confirmed that the implementations had been made and assessed that PAO is now in compliance with Local Law 30. Based on recent improvements, PAO generally meets the needs of the Non-English Language Preference (NELP) population as intended.

Intended Benefits

While the audit found that NELP constituents generally have access to the same PAO services as English-speaking constituents, the audit also found that PAO should create and implement an LAIP and offer translations of PAO reports published on their website.

Introduction

Background

PAO conducts oversight of City agencies, monitors and evaluates the services City agencies provide, develops and publishes policy recommendations for resolving Citywide issues, and investigates citizens’ complaints. Part of PAO’s mission, as stated on its website, is to “fight for equitable access to quality housing, education, and economic opportunity in a healthy, safe environment, and advance equity in the distribution of resources.”

New York City is home to one of the most diverse populations in the world, with more than 3 million foreign-born residents. According to the New York City Department of City Planning, nearly one-half of all New Yorkers speak a language other than English at home, and almost 25% of City residents aged five and over are not proficient in English. For residents with a Non-English Language Preference (NELP), interacting with City government and receiving access to City services can be a challenge.[2] Language services are necessary to ensure that all City residents have equal access to the information and services provided by PAO.

Since 2003, the City government has striven to enhance language access for NELP residents through a series of legislative actions including:

Executive Order No.120 (EO120): EO120, New York’s “Citywide Policy on Language Access to Ensure Effective Delivery of City Services,” was established in 2008, and required all City agencies providing direct customer services to offer language access services.
Local Law 25 of 2016 (LL25): LL25 required all City agency websites to include a translation feature for the most widely used languages in the City, other than English.
Local Law 30 of 2017 (LL30): LL30 required all City agencies that provide direct public or emergency services, to designate a Language Access Coordinator and to develop Language Access Implementation Plans (LAIP). LAIPs consist of the following components: identification and translation of the most commonly distributed public documents; interpretive services, including telephonic interpretation in at least 100 languages; training of frontline workers on language access policies; posting of signage in conspicuous locations about the availability of free interpretation services; and the establishment of an appropriate monitoring and measurement system regarding the provision of agency language services. Agencies were also expected to incorporate consideration of language access in public communications (including emergency notifications, public hearings, and events), and craft widely distributed documents using plain language principles. The law also required agencies to develop their LAIPs using the four-factor analysis and to update their LAIPs every three years.[3]
Local Law 13 of 2023 (LL13): LL13 amends the New York City Administrative Code by adding a new section, 23-1105. This section outlines the requirements and best practices for agencies providing City services to “individuals whose primary language is not English (NELP) arriving in the city and seeking city services.”
The Mayor’s Office of Immigrant Affairs (MOIA) designated Wolof and Pulaar/Fulani as the current “temporary languages” in New York City, as required by Local Law 13, based on data from the Office of Asylum Seeker Operations (OASO).[4] Wolof and Pulaar/Fulani are both considered oral languages with limited use in written format. MOIA recommends that agencies refer to its “Best Practices” to plan ways to utilize video and audio whenever possible, and to prioritize interpretation services for these languages. Agencies under OASO’s coordination, including NYC Emergency Management, NYC Health + Hospitals, and NYC Department of Homeless Services, and other relevant agencies are all required to provide translation and interpretation in “temporary languages.” Wolof and Pulaar/Fulani are part of Language Line Solutions’ telephonic translation services.

Objectives

The objectives of this audit were to determine: (1) whether PAO is providing agency services to the Non-English Language Preference (NELP) population in the languages required by relevant laws, standards, and guidelines; (2) whether the agency’s language access services meet the needs of the NELP population as intended; and (3) whether the NELP population has the same access to government services as English-speakers.

Discussion of Audit Results with PAO

The matters covered in this report were discussed with PAO officials during and at the conclusion of this audit. An Exit Conference Summary was sent to PAO on July 2, 2025, and discussed with PAO officials at an exit conference held on August 5, 2025. We submitted a Draft Report to PAO with a request for written comments. After it was issued, however, PAO disagreed with the manner in which some of its corrective measures were presented in the report. To address those concerns, a revised Draft Report was submitted to PAO on August 29, 2025, with a request for written comments. We received a written response from PAO on September 15, 2025. In its response, PAO agreed with the findings and the five recommendations.

PAO’s written response has been fully considered and, where relevant, comments have been added to the report.

The full text of the PAO’s response is included as an addendum to this report.

Detailed Findings

PAO Generally Provides Language Access Services to NELP Constituents as Required

The auditors found that PAO:

Provides language access services to NELP clients. PAO contracts with two language access vendors for language access services—Language Line Solutions (for telephonic interpretation) and JR Language Translation Services, Inc. (for document translation services). Language Line Solutions can provide interpretation in over 240 languages and JR Language Translation Services can provide translation services in over 100 languages. Both vendors can provide language access services in the City’s top 10 NELP languages, as designated by MOIA. PAO also makes use of multilingual staff to assist NELPs and provide services—of the nine staff members in the Constituent Services Department, five can provide interpretation in Spanish, Haitian Creole, and Polish. PAO also contracts with SignNexus, a national sign language interpretation service vendor.
Notifies the public of the right to free interpretation services. PAO informs the public of the availability of interpretation services in English and the top 10 NELP languages by posting signs in conspicuous, publicly accessible locations within its offices. PAO has a complaint hotline on its website that constituents can use to file complaints or submit inquiries involving government-related services and regulations.

At the time of testing, the webpage translated into over 100 languages but did not indicate that free interpretation was available to constituents who call the hotline.

At the exit conference, PAO officials informed auditors that their website has been updated to include the name and contact information of their Language Access Coordinator. The website was also updated to include instructions to contact the LAC with any questions regarding PAO’s language access services, instructions for submitting any complaints about language access, and to incorporate public awareness strategies. The website now states that PAO can provide “translation at no cost in Arabic, Bangla, Chinese (Cantonese, Chaochow, Fukienese, Mandarin, Shanghai, Taiwanese, and Toishanese), French, Haitian Creole, Korean, Polish, Russian, Spanish and Urdu.” These changes collectively ensure compliance with Local Law 30.

Provides access to pertinent information on its website in over 100 languages. When functioning correctly, the translation feature provided by PAO can translate website text into 104 languages, including English and the top 10 NELP languages. A dropdown menu showing the different language options should appear when the user selects the down arrow next to the word “English” in the top right corner of the webpage. However, when auditors initially tested the translation feature in March 2025, the dropdown menu was not functioning properly, with language options appearing blank. This made it difficult for a user to determine if their preferred language was available (see Figure 1 below).

Figure 1: Screenshot of PAO Website Translation Feature

Auditors informed PAO of this bug and staff promptly corrected it. Auditors tested the feature again in April 2025 and found that it was operating properly, with all language options visible when the dropdown menu was engaged.

Trains its staff in the availability of language access services. PAO gave auditors material used to train staff in accessing and using Language Line Solutions effectively. The material included tips for conducting telephonic interviews with an interpreter. During a site visit, auditors questioned frontline staff about PAO’s intake procedures for NELP constituents. PAO staff demonstrated these procedures, which consisted of identifying constituents that may need language access services, assisting the constituent in identifying their preferred language, and logging the complaint to show that the constituent required language access services. PAO also showed auditors video and written guides that included instructions and best practices for using PAO’s contracted telephonic interpretation service provider. PAO informed auditors that the Constituents Services staff had received language access training; other agency staff are scheduled to receive training in the summer of 2025.

Although PAO staff demonstrated knowledge of language access procedures and were able to perform them during an on-site observation, PAO was unable to show auditors a record of staff who attended language access training, such as sign-in or attendance sheets.

At the exit conference, PAO officials showed auditors sign-in sheets to document that 12 staff members had attended language access training as of August 4, 2025. PAO also incorporated training into its LAIP, which now states that staff are required to be trained yearly in the provision of language access services and the use of PAO’s contracted telephonic interpretation vendor, in compliance with Local Law 30.

PAO Did Not Comply with Several Key Aspects of Local Law 30

PAO’s Most Commonly Distributed Documents Were Not Translatable into the City’s Top 10 NELP Languages

Local Law 30 requires agencies to identify and translate documents that are most commonly distributed to the public. PAO publishes a blog called “The Advocate,” which covers a range of topics aligned with PAO’s mission, including Civic & Community Empowerment; Housing & Health Equity; Infrastructure & Environmental Justice; Education & Opportunity; and Justice & Safety, among others. The audit found that these entries are translatable using the translation feature on the PAO’s website.

However, PAO also publishes reports on its website under the Policy & Legislation tab that are not translatable into the City’s top 10 NELP languages. According to its website, PAO’s Policy Department develops “progressive policy recommendations for city-wide issues such as pay equity, education, and affordable housing” and “monitors and evaluates the services of city agencies and forms actionable solutions to improve their functioning for the benefit of all New Yorkers.” However, while these reports are distributed digitally and accessible on the website, they are not translatable documents—only the report summaries can be translated. When a user clicks a link to the report, they are directed to a page that displays a PDF that does not translate when the translation feature is selected.

PAO informed auditors that translations of reports can be provided to constituents upon request. (As stated above, PAO contracts with JR Language Translation Services, Inc. to offer this service.) However, this accommodation is not stated on PAO’s website, so there is no way a visitor to the site would know that this option is available.

PAO generally did not create printed informational materials for public consumption. Instead, PAO distributes printed materials created by other City agencies, such as voter registration forms (from the Board of Elections); safety training requirements information cards (from the Department of Buildings); and an HIV/AIDS medical resources information card (from the Department of Health and Mental Hygiene).

PAO does generate complaint forms, which are translatable online using the translation feature prior to completion. PAO’s contract with JR Language Translation Services, Inc. allows the agency to translate complaint forms for NELP constituents to complete during in-person visits to PAO’s office, as well as any other documents it may produce and distribute to the public.

At the exit conference, PAO officials provided auditors with copies of constituent complaint forms and language access surveys in each of the top 10 designated citywide languages. These forms will allow PAO to more effectively monitor and respond to any issues or complaints constituents may have with PAO’s provision of language access services and may also allow PAO to evaluate “the language access needs of the population likely to be served,” in compliance with Local Law 30.

PAO staff also informed auditors that they have started the process of uploading publicly accessible reports to their website so that the reports can be translated using the translation feature. These are PAO’s most commonly distributed documents. Auditors confirmed that PAO’s most recent report has been posted and was translatable into the top 10 designated citywide languages, in compliance with Local Law 30.

PAO Did Not Create a Language Access Implementation Plan in Compliance with Local Law 30

Language Access Implementation Plans (LAIP) are used by agencies to outline the provision of interpretation and translation services and to ensure equal access to government services for English-speaking and NELP individuals, as well as agency compliance with applicable laws and regulations. However, PAO had not created or implemented an LAIP in compliance with LL30 prior to this audit.

Auditors obtained a copy of PAO’s Language Access Procedures in March 2025 and found that, while some key aspects of the law are addressed (including descriptions of how PAO will offer language access services and how PAO records language access service requests), the procedures do not include most of the key aspects required by the law. Therefore, auditors concluded that PAO’s Language Access Procedures could not be considered a Language Access Implementation Plan, but rather a template PAO can use to outline what it needs for such a plan.

The elements of LL30 that were not addressed in PAO’s Language Access Procedures include:

stating that the contracted vendor can provide telephonic interpretation (audio interpretation or web-based services) in over 100 languages. During an on-site observation, PAO staff stated that this is possible; however, this information is required to be included in the agency’s LAIP.
ensuring that PAO’s most commonly distributed documents are translated into the top 10 NYC NELP languages using plain language principles.[5]
requiring the name and title of the Language Access Coordinator to be posted in a conspicuous place on the agency’s website. In March 2025, PAO informed auditors that it had designated one of its staff as Language Access Coordinator, as required by LL30, but the name and title had not been posted.
training policy and procedures for annual training of PAO frontline and management staff on the provision of language access services.
incorporating consideration of language access in public communications (e.g., public hearings and events, press releases).
addressing language access needs in PAO’s emergency preparedness and response.
incorporating appropriate public awareness strategies regarding the agency’s language access services.
including a process to monitor and promptly respond to public complaints regarding language access.
updating its LAIP (based on changes in the PAO’s service population or services) at least once every three years and publishing the plan on its website.

An LAIP that incorporates all aspects required by LL30 would more effectively “promote equity in economic opportunity, education, health, civic participation, and all other aspects of the life of the city” as defined by the local law. In a meeting held in May 2025 with the auditors, PAO officials stated that the agency will update their procedures to create a fully compliant LAIP, include the necessary information, and post the plan on its website as required. At a follow-up meeting in June 2025, PAO officials stated they were still working on it but did not provide a target date for when it might be completed.

LL30 also requires agencies to monitor and respond to complaints about their provision of language access services in a timely manner. The auditors found that PAO maintains a spreadsheet containing a record of general complaints filed against other City agencies by constituents who required assistance in a language other than English, but it does not indicate whether PAO monitors or responds to language access complaints, nor does the LAIP account for the monitoring of complaints.

Finally, based on discussions with PAO officials, the agency was unaware that it is required to perform the four-factor analysis issued by the U.S. Department of Justice to assess language access needs and resources needed when creating or updating the agency’s LAIP.

At the exit conference, PAO officials provided auditors with an LAIP. The LAIP was developed using the four-factor analysis and incorporated key aspects of Local Law 30, such as:

designating a Language Access Coordinator;
accounting for interpretation in over 100 languages by both PAO officials and a contracted telephonic interpretation vendor;
translation of commonly distributed documents into the top 10 designated city wide languages;
requiring yearly training for PAO staff;
addressing language access needs in PAO’s emergency preparedness;
incorporating public awareness strategies,
including a process to monitor and promptly respond to public complaints regarding language access; and
requiring that the LAIP be evaluated every three years to make sure that it is in compliance with federal, state, and local law.

Based on these additions, auditors conclude that PAO has created and implemented an LAIP that complies with Local Law 30.