Language Access Plan

The Department of Insurance (“DOI” or “Agency”) has prepared this Language Access Plan (“LAP” or “Plan”) for the purposes of outlining the protocol and procedures taken by DOI to ensure meaningful and universal access to any DOI Program, Service, and Activity on the part of persons who self-identify as having Limited English Proficiency (“LEP”) or preference for materials and services in a language other than English.

DOI considers an LEP person as someone who is not able to speak, read, write, or understand the English language at a level that allows them to interact effectively with the Agency. An LEP person maintains the right to self-identify, as well as the right to indicate their language of preference, particularly as it relates to information technology delivery.

To protect consumers by providing assistance and information, by efficiently regulating the insurance industry's market behavior and financial solvency, and by fostering a competitive insurance marketplace. Embrace efficiency and innovation to educate and protect Illinois insurance consumers and to encourage a vital and robust Illinois insurance market. The department administers a state-based insurance marketplace, ‘Get Covered Illinois’. Its mission is to increase access, enrollment, affordability and choice for individuals and families purchasing health insurance in Illinois.

The Department carries out this mission through effective administration and enforcement of the Illinois Insurance Code (215 ILCS 5/1 et seq.), the Illinois Pension Code (40 ILCS 5/1-101 et seq.), and related laws and regulations, including Title 50 of the Illinois Administrative Code.

It is the policy of DOI to provide Meaningful Access for LEP persons to any DOI Program, Service, and Activity for which they may individually be eligible to participate.

DOI shall provide access to free Language Assistance Services to LEP persons whenever an LEP person requests Language Assistance Services. Upon request, the Agency will inform members of the public that Language Assistance Services are available free of charge to LEP persons and that DOI will provide and make available these services to them.

The purpose of this policy is to establish effective guidelines, similar to the guidance provided by Title VI of the Civil Rights Act of 1964 and Executive Order 13166, for agency personnel to follow when providing services to, or interacting with, persons who have Limited English Proficiency as DOI recognizes the value and importance of providing access to any DOI Program, Service, and Activity.

DOI is committed to providing LEP persons Meaningful Access to any Program, Service, and Activity although they may be limited in their English language proficiency. This Plan describes the Agency's policies and practices to provide language access services to LEP persons. Pursuant to this Plan, the Agency seeks to continue to eliminate or reduce - to the maximum extent practicable - Limited English Proficiency as a barrier to accessing any Program, Service, and Activity, as such, DOI will review and update this Plan, on a biennial (2 year) basis.

This Plan serves to (a) inform DOI staff, contractors, vendors, and client agencies about language access services and support; (b) designate key staff tasked with supporting languages access services for the benefit of DOI, and (c) offer opportunities to further the reach of DOI language access provisions.

To achieve the goal of Meaningful Access to any DOI Program, Service, and Activity by LEP persons, DOI will:

1. perform a needs and capacity assessment;
2. arrange for oral language assistance, as appropriate;
3. translate DOI Vital Documents in languages other than English;
4. update LAP policies and procedures;
5. monitor access to language assistance; and
6. provide staff training on the language service provision.

1. Bilingual Staff - A staff person who has demonstrated proficiency in English and reading, writing, speaking, or understanding at least one other language. For the purposes of this plan, a bilingual staff member is a staff member hired under a position description that requires the use of sign language, Braille, or another second language.
2. Effective Communication - Communication sufficient to provide the LEP person with substantially the same level of services received by persons who are not LEP. For example, staff must take reasonable steps to ensure communication with an LEP person is as effective as communication with English proficient persons when providing similar programs and services.
3. Interpretation - The act of listening to a communication in one language (source language) and orally converting it to another language (target language) while retaining the same meaning.
4. Language Access Plan Coordinator - DOI staff who are responsible for providing Meaningful Access to any of its Program, Service, and Activity to LEP persons.
5. Language Assistance Services - Oral and written language services needed to assist LEP persons to communicate effectively with staff, and to provide LEP persons with Meaningful Access to, and an equal opportunity to participate fully in, the Program, Service, and Activity administered by the Agency.
6. Limited English Proficiency persons - Persons who do not speak English as their Primary Language and who have a limited ability to read, write, speak, or understand English. LEP persons may be competent in English for certain types of communication (e.g., speaking or understanding), but still be LEP for other purposes (e.g., reading or writing).
7. Meaningful Access - Language assistance that results in accurate, timely, and Effective Communication at no cost to the LEP person. For LEP persons, Meaningful Access denotes access that is not significantly restricted, delayed, or inferior compared to any Program, Service, and Activity provided to English proficient persons.
8. Primary Language - A person's primary language is the language in which the person most effectively communicates.
9. Program, Service, and Activity - All of the operations of the Agency.
10. Translation - The replacement of written text from one language (source language) into an equivalent written text in another language (target language).
11. Vital Document - Paper or electronic written material that contains information that is critical for accessing the Agency’s Program, Service, and Activity, or as required by law.

Illinois is home to a diverse population with cultural and linguistic backgrounds from around the world. To support DOI in determining and prioritizing language assistance services, the Language Access Plan includes a Needs Assessment that identifies the languages spoken by individuals with languages other than English served or likely to be served by DOI.

A four-factor analysis is used in this section as a framework to determine the language services DOI needs to prioritize to meet the needs of individuals with limited English proficiency. The four-factor analysis is a tool designed to help recipients of federal financial assistance conduct an individualized assessment that considers the following four factors:

1. Factor 1: Data collection and analysis of the population with limited English proficiency

2. Factor 2: Data collection and analysis of languages encountered

3. Factor 3: Services Provided to General Public and/or Prospective Limited English Proficient Users

4. Factor 4: Budget and Available Resources

Data provided in this section illustrates the number of individuals with limited English proficiency and with LEP who may need language services, as well as the types of services DOI provides that the general public and potential individuals with LEP would access.

Overview of Standards

Limited English Proficient Population Data Collection and Analysis assesses the number or proportion of individuals with limited English proficiency that could be served by or could encounter DOI’s services.

The Illinois Language Equity and Access Act requires each State agency to conduct an individualized assessment to determine the adequacy of its Language Access Plan. This assessment must consider the frequency with which persons with LEP come in contact with services, programs, or activities provided by the agency. In addition, the Act directs the Office of New Americans (ONA), with the support of the Department of Human Services, and any other relevant agencies, to prepare a Language Needs Assessment Report based on available U.S. Census data. This report must identify languages spoken throughout the State and examine the geographic patterns and trend data to inform the development of agency Language Access Plans.  

The Language Access Plan must include a description of the LEP populations served, the policy and programmatic actions taken to ensure meaningful access, and the metrics used to measure compliance with the Act.  Agencies must regularly monitor demographic population changes to ensure language services adequately reflect actual needs, particularly for services frequently utilized by the public.

This analysis helps ensure that DOI is positioned to adequately identify underserved communities with LEP and emerging language needs and address any barriers that may prevent access to critical public services.

Current DOI Systems and Practices

In 2026, DOI is using self-reported data gathered from applications for health coverage, and the following findings from a demographic analysis[1] conducted by the University of Illinois Chicago in partnership with the  ONA on the State’s individuals with limited English proficiency and individuals with LEP:

• In Illinois, 1.0 million residents speak English less than "very well," and speak a language other than English at home. Both federal and state policies recognize that these individuals have a right to equitable access to government services, which includes information and communication in a language they understand.
• Eleven languages have more than 10,000 limited-English speakers in Illinois, including:

Largest Language Groups and Largest Limited-English Language Groups in Illinois: 2018 - 2022

• The predominant language other than English in many Illinois counties may be Spanish, but closer examination of the most common non-English languages shows that immigrants and migrants come to Illinois from many places. For example, in Champaign County, the top language spoken in limited English households is Mandarin, and in Macon County, it is Tagalog. Additionally, in Cass and Knox counties, the second language is French/Haitian/Cajun. In Madison County, it’s Tagalog. In Cook, DuPage, and Kane counties, the second language category is Slavic. In Boone County, “other Asian Pacific Islander” is second to Spanish.
• A statewide map of persons who don’t speak English very well shows that the largest numbers of such persons are in the metro Chicago area. Nevertheless, significant numbers of up to 9 thousand are located in townships across the state and are often located near metro areas such as St. Louis, Springfield, Champaign, and Rock Island. There are also notable populations in relatively rural townships in counties such as Cass, Douglas, or Union.
• After years of decline, the number of Illinois residents who don’t speak English very well is on the rise. In examining ten years, from 2014 to 2023, this population fell by 79,000 persons between 2014 and 2019. But since a low of 1.0 million in 2019, the most recent data, for the year 2023, shows about 1,082,000 persons, for a gain of some 82,000.

Overview of Standard

Language Encounters Data Collection and Analysis assesses the frequency with which limited English proficient (LEP) individuals encounter DOI's services, programs, or activities.

The Illinois Language Equity and Access Act requires State agencies to conduct an individualized assessment as part of its Language Access Plan that considers the frequency with which persons with LEP come into contact with the services, programs, and activities provided by the agency. This analysis supports the DOI’s ability to identify language access needs and ensure meaningful access.

In order to ensure that all DOI encounters with individuals with LEP across programs and services are collected in a comprehensive and ongoing manner, DOI will:

• Collect data on encounters with individuals with LEP that take place in person, by telephone, via email, and through online platforms.
• Track the languages encounters and types of language assistance services requested and/or provided during those encounters; and
• Conduct regular assessments and identify high-volume languages and the most frequently requested or needed language assistance services to ensure meaningful access that is accurate, timely, and effective at no cost to persons with LEP.

Current DOI Systems and Practices

• DOI currently automatically tracks phone calls from non-English speakers to its bilingual staff.
• Language preferences logged via health insurance application.
• All requests for translations of vital documents and live translation services are logged, and language types tracked.
• Annual re-assessment of language access needs and usage.

Overview of Standard

Services Provided to General Public and/or Prospective Limited English Proficient Users, assesses the nature and importance of the programs, activities, or services provided by DOI.

The Illinois Language Equity and Access Act requires State Agencies to implement an individualized assessment as part of their Language Access Plan that includes the nature and importance of the services, programs, or activities provided by the State agency.

To ensure meaningful access to critical and urgent information and services, DOI will outline procedures for prioritizing language assistance for vital and urgent information and activities.  DOI will review all services and information and will prioritize language assistance for programs, activities, services, or information that, if not understood by individuals using languages other than English, could have immediate and/or severe impacts. 

Current DOI Systems and Practices

DOI protects consumers by providing assistance and information. DOI allows insurance customers to file complaints against an insurance company or agent, and investigates workers’ compensation fraud. Customers can file a variety of complaints online or call a hotline. DOI’s website can be translated into many languages, and vital documents can be translated by request via Propio. Our Get Covered Illinois program vendor Marketing for Change provides various Spanish translations.

Through the SBM, DOI also provides access to health insurance coverage to approximately 450,000 state residents. Get Covered Illinois’ website is translated into Spanish and its Customer Assistance Center utilizes Language Line for live call support in over 200 different languages. The CAC had 119 bilingual employees in 2025, and supports live chat in English and Spanish via bilingual staff.

Overview of Standard

Budget and Available Resources assesses the resources available to DOI currently, as well as the cost associated with providing the language assistance.

The Illinois Language Equity and Access Act requires State Agencies to review the resources available to the State Agency and the costs. It is best practice for the budget for language access services to be based on programmatic needs and the top five languages prioritized for services.  Additionally, a strategic practice is to outline the costs associated with current language assistance services, as well as assess the level of resources, costs, and capacity to implement and support additional language services over time. Based on the assessment of resources, DOI will identify efforts to support cost-savings and cost-sharing when/if needed. Such efforts may include sharing resources with other departments and agencies and/or using technology to support the delivery of language assistance services.

Current DOI Systems and Practices

The Language Access Coordinator reviews the cost of translated services annually. Translated documents and translators are provided via the CMS Master Contract, at a cost of $1,600 in FY 2025. DOI employs nine (9) bilingual staff at a cost of $ 556,452 annually.

Effective Communication with LEP persons requires DOI to have Language Assistance Services in place. There are two primary types of Language Assistance Services: oral and written.

Oral Language Assistance Services may come in the form of “in-language” communication (a demonstrably qualified Bilingual Staff member communicates directly in an LEP person’s language) or Interpretation.

Translation is the replacement of written text from one language into another. A translator also must be qualified and trained.

DOI’s Plan is overseen by the LAP Coordinator and will be implemented throughout the Agency to provide Meaningful Access to persons limited in their English language proficiency. A LAP Coordinator is assigned to coordinate not only language assistance, but also provide technical assistance in navigating DOI’s processes, procedures, and understanding the language access requirements of the Agency.

Each Program, Service, and Activity of DOI identified provides Over-the-Phone (OPI) interpreting for over 200 languages as well as Video Remote Interpreting (VRI) for American Sign Language. VRI can be used on a PC via a provided web address or on a Tablet or Smartphone by loading the Propio app.

The Get Covered Illinois CAC had 119 bilingual employees in 2025, providing support in both English and Spanish. In addition, customer service representatives have access to Language Line services, which offer over-the-phone translation in up to 200 additional languages.

Translators working through Language Line are assessed using language and bilingual proficiency tests, including an oral proficiency interview that evaluates grammar, vocabulary, syntax, fluency, and overall language competence. These evaluations follow the Interagency Language Roundtable (ILR) rating scale.

Competency of Bilingual Staff - Bilingual Staff will be assessed for bilingual proficiency, Interpretation skills, and sensitivity to the special confidentiality issues raised by interpreting for others. Components should ensure that individuals providing interpretative services possess a level of fluency and comprehension appropriate to the specific nature, type, and purpose of information at issue. DOI currently employs nine (9) bilingual staff members. For the purposes of this plan, a bilingual staff member is a staff member hired under a position description that requires the use of sign language, Braille, or another second language, or has been certified as bilingual.

Unacceptable practices – DOI should not use family members or friends to translate or interpret for LEP persons. If the LEP customer insists upon using a friend or family member, it should be allowed only after language services have been offered and refused. Minor children should never be used to interpret, except in emergencies.

DOI’s website provides machine translation for all visitors.

DOI’s vital documents were identified with the input of agency leaders, and include the following: 

In addition to providing language assistance services, the Notification of Language Assistance Services section will outline how DOI can notify the public of language assistance services and provide information on how language assistance services can be requested. Such communication will assist individuals with LEP in understanding the services provided by DOI, which can increase public trust and confidence.

Overview of Standards

The Illinois Language Equity and Access Act requires State Agencies to ensure that the general public and individuals with LEP are informed of the availability of free interpretation and translation services and how to request them. To meet this requirement, DOI will provide multilingual public notices in various formats—both digital and physical—to promote broad public awareness. All notices will clearly explain how individuals can request interpretation or translation services and will be made available in the most frequently spoken languages identified through demographic analysis and the State’s Language Needs Assessment Report.

Current DOI Systems and Practices

DOI utilizes physical pamphlets/flyers in public areas, a notice of the machine translation feature on its website’s homepage, a Spanish translation of greetings in its website interactive chatbox, and invites Spanish speakers who call the agency to access a Spanish version of the call menu. DOI does not currently conduct any public outreach events. 

DOI will train front-line and managerial staff on the policies and procedures of its LAP. Front-line staff will be employees whose routine duties include interactions with the public. Staff will receive training on the policies and procedures of language assistance and on how to determine whether Language Assistance Services are needed by a customer. In addition, staff will receive training on how to secure Language Assistance Services for a customer.

If applicable, when a specific DOI Program, Service, and Activity is identified as warranting Language Assistance Services, then the Agency will develop specific written policies and procedures related to Language Assistance Services applicable to that Program, Service, and Activity.

Written policies and procedures may address the following areas:

a.  provision of language services generally;
b.  identification and assessment of language needs;
c.  staff training on language service provision; and
d.  monitoring access to language assistance.

Currently, DOI automatically tracks phone calls from non-English speakers to its nine frontline bilingual staff. The DOI webpage displays an auto-translate feature prominently in the top right hand corner, with machine translation in the six most commonly used non-English languages.

All requests for translations of vital documents are logged, and language types tracked. For other, non-Spanish, languages for which OSFM does not have in-house interpreters or translators, DOI currently has contractual arrangements in place for translator and interpreter services. A request can be made by LEP individuals, or DOI staff may recognize that an interpreter is needed to assist LEP individuals and request an interpreter at interpreter@propio.com.

To the extent applicable, each DOI Program, Service, and Activity identified in Section 5 as warranting Language Assistance Services will institute procedures to monitor the accessibility and quality of language assistance activities for LEP persons.

Data collection and record keeping are key to an effective monitoring and compliance system. To determine the validity of any language assistance complaints, it may be necessary to analyze and review data that reflects how the program provides services to LEP persons. Data collection also allows the program to obtain an overview of how its services are provided.

To the extent applicable, each DOI Program, Service, and Activity identified in Section 5 as warranting Language Assistance Services will develop and maintain a data collection system that assures the availability of data that includes race, ethnicity, and the Primary Language of the LEP person.

Such data should include the data upon which the program has based the language needs assessment; the number of LEP persons, by language group, who received language services; names and categories of staff receiving training, and dates of training.

The Concern Resolution Process Section of the Language Access Plan highlights the need for allowing public feedback on the quality, accessibility and effectiveness of language assistance services to address any concerns that arise. This section outlines how DOI will develop and make publicly available a multilingual concern resolution form, collect and log complaints submitted by individuals with LEP and others, and promptly investigate and address each concern in a timely manner.  Additionally, this section describes how the DOI will track the resolution status of complaints to ensure transparency and accountability and coordinate with the ONA when appropriate to support compliance and continuous improvement.

Overview of Standards

The Illinois Language Equity and Access Act requires State Agencies to establish and make publicly available a process for individuals with limited English proficiency (LEP) and members of the public to submit concerns related to access to language assistance services. Section 15(b)(5) of the Act requires each State agency to develop an internal complaint and review process specific to the provision of language assistance services. Complaints that are not resolved in a timely or satisfactory manner may be referred to the Governor’s Office of New Americans for further review, per Section 30(c) of the Act.

Current DOI Systems and Practices

Individuals may file a complaint with the LAC free of charge if they believe they have not received meaningful access to a DOI service, program, or activity.  A written complaint must be filed within 6 months of the alleged denial and sent to the following:

Department of Insurance
Language Access Coordinator
115 S. LaSalle Street, 13th Floor
Chicago, IL 60603

The LAC will follow up with the client in regard to next steps within two weeks of the submission of the complaint. A resolution plan and timeline should be included in the follow up. The resolution of a complaint should not take longer than three months.

In addition, if the individual believes that their complaint is not being resolved in a timely manner and/or CMS’s resolution is inadequate, the individual can elevate the complaint free of charge to:

Illinois Governor’s Office of New Americans (ONA) GOV.NewAmericans@illinois.gov

ONA may engage in an informal process including mediation, conference, and conciliation to resolve the Complaint.

Overview of Standard

In accordance with the Illinois Language Equity and Access Act, DOI will coordinate with the Governor’s Office of New Americans (ONA) to review and monitor the implementation of its Language Access Plan and ensure ongoing compliance with the Act.

DOI will conduct an individualized assessment of language assistance needs and patterns of language use on an ongoing basis and incorporate updated data and performance metrics into each new iteration of the Language Access Plan, as required under Section 25(d)(3). The agency will use this information to evaluate the effectiveness of current policies and practices and to inform continuous improvement of language access services.

The plan will include the ongoing review of statewide and agency-specific data on limited English proficient (LEP) populations, including demographic shifts and the identification of new or emerging language needs, as outlined in the State’s Language Needs Assessment Report. The monitoring and evaluation plan will also track progress on the implementation of Language Access Plan goals, review expenditures related to language assistance services, and assess whether projected changes in costs require budget adjustments or modifications to service delivery methods. Data will be collected and reviewed using the following methods:

Current DOI Systems and Practices

DOI’s language access coordinator will monitor and track data regarding language access use and costs on an annual basis, using a spreadsheet, and will coordinate with the ONA on any improvements or alterations to DOI’s Language access plan. 

The LAP Coordinator (information below), a designee of the DOI Director, is charged with overseeing the Agency’s LAP initiatives, serves as point person internally and externally for the implementation and compliance of the Plan.

Matthew T. Goldie
Language Access Plan Coordinator
(217) 720-7186
Matthew.T.Goldie@gmail.com

DOI is committed to providing Meaningful Access to any of its Programs, Services, and Activities. This carries particular weight in relation to persons with LEP, who may be particularly vulnerable to discrimination and unaware of, or reluctant to take advantage of, available legal protections. DOI will provide outreach and education, assess Plan performance, and, as needed, adjust the Plan accordingly.

To fulfill DOI's commitment to social responsiveness, DOI staff understands the language needs of those accessing the Program, Service, and Activity within DOI’s jurisdiction as being critical to its mission.

There are a number of ways to determine if an individual is Limited English Proficient:

• LEP person self-identifies as LEP; and/or
• LEP person requests an interpreter; and/or
• During the first point of contact, IDFPR staff believes that the individual does not speak and understand English well enough to effectively participate in the conversation or fully understand questions and answers them with difficulty.

Department front-line staff at the point of first contact with a LEP-possible person shall make an initial assessment of the need for language access services by taking the following steps:

1. The staff member shall ask professional, open-ended questions of the LEP-possible person to determine the individual’s ability to speak or understand English. Open-ended questions are those that require a complex, non-static response; these are typically of the “who,” what”, “when,” “where,” and “why” variety. Examples of questions include: “What kind of assistance do you need from IDFPR?” and “Are you applying for a new license or are you an existing licensee?”
2. If the staff member determines that the LEP-possible person is proficient in understanding and speaking English, he or she shall ask the LEP-possible client whether he or she needs assistance in reading or writing English.
3. If the LEP-possible person makes an oral or written request for translation or interpretation services in a specific language, the client should be considered as LEP.
4. Once it is determined that the individual is LEP. The staff member shall assess the type and nature of the language(s) in which the individual is proficient, and whether the person requires translations services, interpretation services, or both. The staff member should utilize the “I Speak…” card available at reception.
5. Although use of informal interpreters—such as family members or the internet—should be avoided, staff members may utilize such for the purpose of assessing an individual’s LEP status.
6. The staff member should proceed with documenting and individuals LEP status and whether language access services were needed, more specifically the type of services rendered. The information should include the LEP person’s name, the person’s language of choice, and the specific language assistance needed/utilized.