March 27, 2002 Ms. Deeana Jang Dear Ms. Jang: This letter is in response to the policy guidance on Title VI’s prohibition against national origin discrimination as it affects Limited English Proficient (LEP) persons issued on February 1, 2002. After reviewing the guidance carefully, we have concluded that enforcement of these regulations would be detrimental to patient privacy and may have the opposite effect of their intention. For these reasons, expanded upon below, we strongly oppose the LEP regulations. In conclusion, the LEP guidance would infringe on the privacy of LEP persons, significantly drive up costs for providers, and undermine the patient/physician relationship. Furthermore, the guidance has the potential to limit access for LEP persons, precisely the opposite effect than intended. For these reasons, we strongly recommend the Office of Civil Rights and Department of Health and Human Services not adopt the LEP guidance as written. Sincerely, Grace-Marie Turner
Attn: LEP Comments
200 Independence Avenue, SW
Room 506F
Washington, DC 20201
President