The accuracy of machine interpretation and translation (e.g. Google Translate) continues to improve. These apps are downloadable to mobile devices and can be helpful in communicating with people in their own language. However, in a federally-assisted setting, there are some strict limitation on their use that should be observed.

Federal LEP guidance requires that all communication relating to accessing programs and services (including housing) must be competent and performed by someone who is ‘qualified’ to provide interpretation and translation.

However, informal conversations unrelated to the “meaningful access” to federally- assisted programs and services are not governed in this way. These apps can help you establish rapport with a LEP tenant just as you would with an English-speaking tenant. The benefit of this should not be overlooked.

However, when the conversation turns to accessing federally-assisted programs and services then a provider must would be well-advised to rely on a human interpreter or translator for help.

The owners of these apps acknowledge their shortcomings. Also, be aware that conversations using machine interpretation are not confidential. They are subject to review by the app owner.

In a civil rights case involving four Massachusetts housing authorities, HUD stated:

Internet translation services may be used for:

    • i. Communication on a preliminary or conventional basis (e.g. “good morning” “what language is that” “do you need an interpreter” etc.);
    • ii. Communication of mundane information (e.g. “this is your parking space number” “this document has five pages” “we provide housing” etc.);
    • iii. Simple requests for basic information (e.g. “what is your name” “what is your phone number” “what time can we call you”).

Artificial Intelligence (AI)

AI may become a transformative technology for language access. But experts caution that it has some of the same competency and confidentiality issues as the internet translation apps. Until HUD or USDoJ advises differently, AI use should be restricted as a best management practice.