Title VI Language Access Plan Consulting for State and Local Agencies After Executive Order 14224

Yes, in a narrower form. Title VI still bars national-origin discrimination by any agency that receives federal funds, and the Justice Department’s April 2025 rescission notice says denial of language assistance services “can be evidence of discrimination on the basis of national origin or disability under certain circumstances.” What changed is enforcement: federal agencies now pursue intentional discrimination, not disparate impact. Program rules and state and local law still apply in full.

Almost certainly, if you receive federal funds or work in a state or city with a language access law. For most agencies no federal rule requires the plan document itself, though FTA’s transit circular, the Section 1557 rule for health programs (45 CFR 92.8(d)) and several state laws do. The plan is how you show you meet obligations that still exist. Dropping it removes your evidence, not your obligations.

Not directly. Executive Order 14224 directs federal agencies. It revoked EO 13166 and told the Attorney General to replace federal language access guidance, and it states that “nothing in this order, however, requires or directs any change in the services provided by any agency.” State and local agencies feel it through federal funding, reviews and enforcement, not as a rule of their own.

No. Executive Order 13166 of August 11, 2000 was revoked by Executive Order 14224 on March 1, 2025. A plan that cites EO 13166 as its authority should be re-based on the obligations in force today.

Yes. The Justice Department rescinded its 2002 guidance to funding recipients on March 21, 2025, and the Attorney General’s July 14, 2025 memorandum rescinded its remaining language access guidance, told other agencies to review theirs and suspended LEP.gov. The memorandum promised new guidance for public comment; none had appeared as of September 26, 2026. HUD, Treasury and DHS have also withdrawn their guidance to recipients.

As of September 26, 2026, FTA still lists Circular 4702.1B, which asks recipients for a Title VI Program that includes a Language Assistance Plan based on a four-factor analysis, and it has published no change. The Department of Transportation removed its disparate-impact provision on June 11, 2026, so we write your plan to hold whether or not FTA revises the circular.

It weighs four things: the number or proportion of people with limited English proficiency you serve or are likely to meet, how often they contact you, how important the program is to their lives, and your resources and costs. It came from the rescinded federal guidance, but it remains the clearest way to show your choices were reasonable, and FTA’s circular still uses it.

The former Justice Department guidance treated translating vital documents for each language group of 5 percent or 1,000 people, whichever is less, as strong evidence of compliance. That federal guidance was rescinded in 2025. The same test survives in state and local law: Hawaii uses 5 percent or 1,000, Illinois more than 5 percent or 1,000, and Boston 5 percent or 1,000.

Any document critical to getting or keeping a service or benefit, or required by law: applications, consent and complaint forms, notices of rights, eligibility and denial letters, notices of hearings and deadlines, and emergency and public-safety information. Your plan should list them by name and program, with the languages each must be in.

For low-risk, informal content with a notice, sometimes. For vital documents, not without review by a qualified human translator. Health programs are already bound by that rule under 45 CFR 92.201(c)(3). Machine output in Pashto and Dari is less reliable than in major languages, so your plan should say which content may be machine-translated and who checks it.

Bilingual staff can, if your plan requires them to pass a language and interpreting assessment first; speaking a language is not the same as interpreting. Family members and friends should interpret only in an emergency, and children never. Michigan’s 2023 law says interpreting by a relative, friend or bystander does not meet its requirements for state agencies.

No. Pashto is a separate language, not a dialect of either. Dari is the Persian of Afghanistan and Farsi the Persian of Iran; they differ in everyday words, official terms and pronunciation, and a Farsi interpreter can miss meaning with an Afghan resident. List Pashto, Dari and Farsi separately. Pashto is the single most reported home language among Afghan immigrants, at 32%.

Not from the standard Census tables. Table B16001 puts Pashto in “Other Indo-European languages” and counts Dari inside “Persian (incl. Farsi, Dari).” Use the ACS microdata, where Pashto (1327), Dari (1292) and Farsi (1290) have their own codes. Its smallest areas hold about 100,000 people, so combine it with your intake language fields, interpreter logs, school home-language surveys and resettlement data.

State laws cover state agencies in California, Hawaii, Illinois, Maryland, Michigan, New Jersey, New York, Delaware, Minnesota and Nevada, and in the District of Columbia; Massachusetts acts by executive order, and Washington’s 2026 law phases in through 2028. Cities including New York, San Francisco, Oakland and Boston have ordinances. Their tests differ, so your plan must meet the one that applies to you.

A review of an existing plan against current law takes three to four weeks. A full plan for a county, city or state agency typically takes ten to fourteen weeks. Cost depends on the departments and programs covered, the languages over your threshold, the volume of vital documents, community engagement and training, and we scope it after one call with your coordinator.

No. Our plans set standards, not vendors: they say what a qualified interpreter or translation must meet, never who supplies it. We declare our interest in interpreting and translation work on every deliverable, and where your procurement rules bar the author of a specification from bidding on the work it describes, we step aside from that work.