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interpreter, translate vital documents, and utilize community volunteers. After analyzing the Town of Hamburg budget and reviewing available resources, cost associated to meet language assistance needs of the LEP population at 5% or greater will be incurred for translating vital documents. For languages that do not meet the 5% threshold, the cost of interpretive services will be considered on a case-by-case basis. Results of the Four Factor Analysis As a result of the four-factor analysis, a written Language Assistance Plan is not required. However, reasonable attempts will be made to accommodate any persons encountered who require written translation or oral interpretation services. Our agency will do this at no cost to the program clientele. Further, we will work with other agencies to identify resources that will effectively meet the needs of LEP individuals. During the registration process, Town of Hamburg is able to identify non-English speaking clients with whom we have frequent contact; and therefore, have language assistance tools or staff available to provide oral interpretation. Training Employees to Provide Language Assistance Town of Hamburg employees are oriented on the principles of Title VI and language assistance at hire and when the Title VI plan is updated. New employees will be provided guidance on the needs of clients served and how best to meet their language needs. Training will include review of the following Title VI program components: 1. Title VI Notice to the Public 2. Title VI complaint procedures and form 3. Complaint log 4. LEP and Language Assistance Plan If an employee needs further assistance related to LEP individuals, they will work with the Town of Hamburg’s Title VI Coordinator to identify strategies to meet the language needs of the participants of the program or service. B7. Minority Representation on Advisory Boards Town of Hamburg has no transit-related, non-elected committees or advisory councils. B8. Recordkeeping and Reporting Town of Hamburg maintains records related to the agency’s implementation of Title VI program, including records of the Title VI Plan adoption and approval (see section B5), records of Title VI staff training, public involvement activities, complaints, investigations, language assistance services and other implementation activities. Town of Hamburg shall update the Title VI Plan, every three years and submit the plan to the New York State Department of Transportation (NYSDOT) for approval. B9. Plan and Policy Review The Title VI policy will be disseminated to employees through training at new employee orientation and every time the plan is updated. The Town of Hamburg will review its Title VI Plan at least once every three years to determine if modifications are necessary. The Town of Hamburg directly operates and will review implementation annually to ensure compliance with Title VI Plan requirements. The agency’s review includes verifying that all employees have Town of Hamburg Title VI Plan Page 13 Open-Door Services 89