Audit Report on the on the Compliance of the New York City Department of Health and Mental Hygiene with Local Law 30 Regarding Access to City Services for Residents with Limited English Proficiency

Executive Summary

In 2017, the New York City Council enacted Local Law 30, effective July 1, 2017, which requires New York City (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 10 designated Citywide languages, consisting of the top 6 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, based on U.S. census data, and the top 4 limited English proficiency languages spoken by the population served or likely to be served by the agencies of the City of New York, excluding the languages designated based on U.S. census data.

This audit focuses on whether Department of Health and Mental Hygiene (DOHMH) complied with Local Law 30. DOHMH is responsible for protecting and promoting the health and well-being of all New Yorkers. Among other things, DOHMH joins with communities to develop and implement public health programs, enforce health regulations, respond to public health emergencies and provide limited direct public services such as critical preparedness and response roles, with the primary goal of protecting the public’s health. Direct public services, such as tuberculosis testing and treatment, seasonal flu shots, and childhood and adult vaccinations are provided at four tuberculosis clinics, eight sexual health clinics, one immunization clinic, and more than 1,200 public schools. In addition, DOHMH issues birth and death certificates, and inspects restaurants and child care centers. DOHMH attempts to reduce deaths and disabilities from chronic diseases, such as heart disease and cancer, by educating New Yorkers about the dangers of smoking, the consumption of unhealthy foods, and the benefits of physical activity. DOHMH also contracts with community-based organizations to deliver mental health, developmental disability, and alcohol and substance use disorder treatment services.

Audit Findings and Conclusion

We found that DOHMH generally complied with Local Law 30. Our review of DOHMH’s Language Access Plans dated 2009 and 2018 found that DOHMH has made continuous progress to provide meaningful language access to the agency’s services for Limited English Proficient (LEP) customers. Its Language Access Plans describe the steps that DOHMH has taken to provide its services to the LEP population.

Specifically, we found that DOHMH provides direct public services in 13 languages including the top 10 New York City LEP languages as required by Local Law 30.  Further, we found that through City-wide contracts with language vendors, (Language Line Services, LLC and Geneva Worldwide, Inc.) and by utilizing the City’s Volunteer Language Bank and agency staff, DOHMH has the ability to provide documentation, translation and phone interpretation services in 240 languages. Through its contract with Accurate Communications, DOHMH can provide American Sign Language interpretation. Appendices I and II contain details of the specific items we tested and the results of our tests. Appendix III illustrates DOHMH’s efforts to ensure compliance with Local Law 30.

Audit Recommendations

To address these issues, the audit recommends that DOHMH:

• Continue to adhere to Local Law 30 to ensure that it adequately meets the language needs of the communities it serves.
• Continuously update its website to ensure that it contains only the locations that are serviced by DOHMH.

Agency Response

In its response, DOHMH agreed with the audit’s findings and recommendations. DOHMH stated, “DOHMH is committed to complying with Local Law 30 to ensure that it adequately meets the language needs of the communities we serve. We will ensure that our website is continuously updated and contains only the locations that are serviced by DOHMH.”