Auxiliary Aids Plan
Coast to Coast Legal Aid of South Florida, Inc.
Family Law and Domestic Violence Unit
The Family Law and Domestic Violence Unit of Coast to Coast Legal Aid of South Florida (hereinafter Domestic Violence Unit) shall comply with Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, as implemented by 45 C.F.R. Part 84 (hereinafter referred to as Section 504) and the Americans with Disabilities Act of 1990, 42 U.S.C. 12131, as implemented by 28 C.F.R. Part 35 (hereinafter referred to as ADA).
This plan will be posted on CCLA’s website and is available in alternative formats at the request of staff and participants. This plan will be distributed upon request to participants or organizations serving persons with disabilities or who are Limited English Proficient.
Single Point of Contact (SPOC)
The SPOC, Heidi Vainio, will ensure effective communication with Deaf or hard-of-hearing customers or companions in accordance with Section 504 and the ADA. The SPOC shall ensure that employees are aware of the requirements, roles, responsibilities, and contact points associated with compliance with Section 504 and the ADA.
Provision of Auxiliary Aids and Services
The Domestic Violence Unit recognizes that the customer or companion’s preference is the primary consideration in determining what auxiliary aids or services to provide. If communication through a specific auxiliary aid or service is deemed to be ineffective, staff will ask the customer or companion to determine a more effective auxiliary aid or service for communication. Documentation shall be made in the customer’s file regarding the attempt to improve the effectiveness of auxiliary aids and services.
If a participant or companion is Deaf or hard of hearing, Domestic Violence Unit’s staff shall obtain auxiliary aids according to the communication assessment and requests for services. All ASL interpreters’ certifications shall be verified.
Staff that is unfamiliar with the auxiliary aid or service requested shall contact their Single Point of Contact (SPOC), 504/ADA Coordinator (Civil Rights Officer) or their Supervisor, for assistance in locating appropriate resources to ensure effective communication with clients, customers and companions.
Provision of Interpreters in a Timely Manner
Domestic Violence Unit’s staff shall provide interpreters for customers and companions who are Deaf or hard-of-hearing in a timely manner in accordance to the following standards:
- Non-Scheduled Interpreter Requests: For any emergency situation that is not a scheduled appointment, staff shall make an interpreter available as soon as possible, but in no case later than two (2) hours from the time the customer or companion or staff requests an interpreter, whichever is earlier. If the situation is not an emergency, staff shall offer to schedule an appointment (and provide an interpreter where necessary for effective communication) as convenient to the customer or companion, but at least by the next business day
- Scheduled Interpreter Requests: For scheduled events, staff shall make a qualified interpreter available at the time of the scheduled appointment. If an interpreter fails to appear for the scheduled appointment, staff shall take whatever additional actions are necessary to make a qualified interpreter available to the customer or companion who is Deaf or hard-of-hearing as soon as possible, but in no case later than two (2) hours after the scheduled appointment
Auxiliary Aids Documentation
Domestic Violence Unit shall document the customer or companion’s preferred method of communication and any requested auxiliary aids and services provided in the customer’s program file. Documents and forms evidencing when and how the family law unit staff provided auxiliary aids and services to customers or companions shall be retained within the customer’s corresponding file for seven years. Forms include but are not limited:
- Customer or Companion Assessment and Assessment and Auxiliary Aid and Service Record
- Customer or Companion Request for Free Communication Assistance or Waiver
- Customer or Companion Feedback form
- Auxiliary Aid Service Record Monthly Summary Report
This documentation will continue to be kept for record keeping with the SPOC.
Denied Auxiliary Requests
Documentation, with supporting justification, must also be made if any request was not honored. CCLA’s Executive Director or the Supervising Attorney for Family Law and Domestic Violence Unit are the only persons that can deny auxiliary aid requests made by a customer or companion. If a staff person is not familiar with an auxiliary aid request, please contact the SPOC for information as well as ask the survivor for any information that you may need to secure this aid, but reiterate that the cost of any auxiliary aid is the responsibility of the firm and not the participant.
If customers or companions are referred to other agencies, the provider must ensure that the receiving agency is notified of the customer or companion’s preferred method of communication and any auxiliary aid or service needs. In order to accommodate this, Domestic Violence Unit will ensure that the referral is desired by the participant and that he or she signs a Release of Information Form.
Customer Feedback Form
The provider shall distribute Customer/Companion Feedback Forms to customers or companions that are Deaf or hard of hearing and provide assistance in completing the forms if requested by the customer or companion. The original Customer/Companion Feedback Form shall be mailed to DCF, Office of Civil Rights, 1317 Winewood Boulevard, Building 1, Room110, Tallahassee, FL 32399-0700 by the participant or if requested, by the Domestic Violence Unit. A copy of the Customer Feedback Form shall not be kept in the file.
Records relating to auxiliary aids and services provided shall be retained by the SPOC and the original document retained in the client or customer’s file or records. A requested sampling of final requests for accommodations, along with relevant documentation, will be forwarded to FCADV.
The SPOC will ensure that conspicuous Notices which provide information about the availability of appropriate auxiliary aids and services at no-cost to the Deaf or hard-of-hearing customers or companions are posted near the receptionist where people sign up. The SPOC’s name and contact information should be on the Deaf and Hard of Hearing Poster as well at the name and contact information for the ADA 504 Coordinator.
The approved Notices can be downloaded through the Internet at: http://www.dcf.state.fl.us
The SPOC shall submit HHS Reports monthly, no later than the 5th day of each month, to the FCADV Contract Manager.
Domestic Violence Unit shall ensure accessibility to meetings, conferences and seminars to persons with disabilities, limited English proficiency, and Deaf or hard of hearing by placing the following statement on all event notices and advertisements prior to the event:
CCLA’s Family Law and Domestic Violence Unit will provide accommodations, including American Sign Language interpreters, assistive listening devices and alternative formats of printed materials and upon request for persons who are deaf, hard of hearing or are living with disabilities. To ensure accommodations, please make your request within 7 days prior to the event to Heidi Vainio at firstname.lastname@example.org.
The Domestic Violence Unit’s staff shall receive training on how to provide auxiliary aids and services for persons with disabilities and limited English proficiency (LEP) within 60 days of commencing employment. Domestic Violence Unit’s staff shall receive an annual refresher training on auxiliary aids and services for persons with disabilities and limited English proficiency (LEP). Training documentation shall be maintained in each employee’s training file.
Florida Relay – 7-1-1
Through the Florida Relay Service, people who use specialized telephone equipment can communicate with people who use standard telephone equipment. To call Florida Relay, dial 7-1-1, or use the appropriate toll free numbers below:
1-877-955-8707 (French Creole)
Video Remote Interpreting
Through a video remote interpreter people can use an interpreter via technology to communicate with a participant in stead of an in person interpreter. This is a good resource for emergency situations with limited time to get an in person interpreter as well as if there are few local community resources for certified interpreters. Below is the phone number for the Registry of Interpreters for the Deaf which will provide contact information for certified video remote interpreting.
Registry of Interpreters for the Deaf: (703) 838-0030 (Video Remote Interpreters)
CART-Captioning Real Time and Providers
Captioning (Real Time). This is the simultaneous conversion of spoken words to text, through computer-assisted transcription or court reporting, and displaying that text on a video screen. This communication service is beneficial to individuals who are Deaf or hard-of-hearing that do not use sign language or for whom assistive listening devices and systems are ineffective.
Brandi Kent, RPR, CBC, CRR, CCP
Tanya Ward English, CRR-CCP-CBC email@example.com
Florida Realtime Reporting
Marianne E. Sayers, RPR, CRR
Fort Myers Court Reporting
2231 First Street
Fort Myers, FL 33901
Creative Interpreting Resources
Certified Sign Language Interpreters:
Interpreter must provide Certification Credentials with him/her for verification and copies provided for client file and SPOC.
CODA Link, Inc. (954) 423-6893
Donna Fernandez, Certified
Ideal Interpreting Services, Inc. (954) 736-6680
Jennifer Harper , Certified
Florida Registry of Interpreters for the Deaf (RID):
(703) 838-0030 (Voice)
(703) 838-0459 (TTY)
For Limited English Speaking Survivors:
Please use the following service:
Optimal Phone Interpreters (OPI)
Know the language that is needed
Be prepared to brief the interpreter about the nature of the call before he/she speaks to your Limited English Speaker.
If you have non English Speaker on the phone call OPI and connect a 3 way call.
For outbound calls, provide the operator with a dial out number and she will make a 3 way conference call
How to Make a Call to OPI:
Dial 1-877-746-4674 you will be asked
- What language you need
- Where you are calling from
- What is your first and last name
- What is the code number for your agency
During the Call:
- Speak in short phrases or sentences
- Avoid slang, jargon, and technical terms
- Check for understanding from you Limited English Speaker throughout the call. If needed, rephrase the questions or statements until understood
- When speaking to the interpreter, do not give and/or ask too much information at one time.
- Ask questions in the first person
Ending the Call:
Be sure the Limited English Speaker and Optimal Interpreter know that the call is ending.
Any applicant or participant who believes he or she has been denied services based upon an unlawful discrimination may file a written complaint with CCLA’s Title VI compliance officer Deborah Eaton using the Denial of Assistance Grievance Form. CCLA shall follow the procedures set forth in its Grievance Procedure which is provided to all applicants for service.
In addition to the above, discrimination complaints may also be filed externally with the state and federal government.
Assistant Staff Director for Civil Rights
1317 Winewood Boulevard
Building 1, Room 110
Tallahassee, FL 32399-0700
Florida Commission on Human Relations
2009 Apalachee Parkway, Suite 100
Tallahassee, FL 32301-4857
US Department of Health & Human Services
Office for Civil Rights
Atlanta Federal Center, Suite 3B70
61 Forsyth Street, SW
Atlanta, GA 30303-8909
US Department of Justice
Coordination & Review Section
Civil Rights Division
P.O. Box 66118
Washington, DC 20035-6118