By Cadhla McBride in Interpreter Access Project — 13 Sep 2026

Monroe County Sheriff's Office Interpreter Access Review

Record boundary: This review reflects records reviewed by TLE through September 12, 2026. Later records may change any finding below.

Executive Summary

Among the agencies reviewed in this audit to date, the Monroe County Sheriff's Office has one of the more developed written Deaf and hard-of-hearing communication frameworks. The production includes General Order MBGO-093-16, two current outside interpreter-service agreements, a Police Bureau bulletin explaining how personnel obtain in-person interpreting, and disability-awareness training curriculum and handouts.

The finding here is not missing policy or missing interpreter infrastructure. MCSO has both, and the framework is specific rather than aspirational. It addresses communication-method selection, qualified interpreters, video remote interpreting, TTY/TDD access, limits on using family members, and reporting requirements that identify the data points a reviewer would need.

What the production does not contain is the operational layer those same documents call for. MBGO-093-16 directs personnel to record when an interpreter was called and when the interpreter arrived and departed. The Tellmorr agreement independently requires the vendor to maintain the requester's identity, the request date and time, the service date and time, the language, the interpreter used, and the cost. No encounter-level documentation and no vendor service records were produced.

At least three explanations are consistent with that result. Responsive records may exist but were not produced. They may not be generated or centrally maintained in a form that permits review. Or some operational records may not have been treated as responsive to the requests that produced these materials. The record does not resolve which.

MCSO's interpreter-access system is documented as a written and contractual framework. Its operation is not auditable from the record.

On September 12, 2026, TLE provided Monroe County and MCSO formal notice of this operational-verification gap. Read the notice.

Download the MCSO agency dataset (.xlsx).

Scope, Records, and Method

This review is based on records obtained under the New York Freedom of Information Law, principally the County's combined response to FOIL 26-1840 and FOIL 26-1946. The County incorporated MCSO's materials into its own response, so the MCSO policies, contracts, bulletins, and training records discussed below reached TLE through the County.

FOIL 26-1840 sought records of Monroe County's central language-access compliance function concerning MCSO. FOIL 26-1946 sought MCSO interpreter-procurement records.

The requests sought, among other categories, any MCSO-specific language-access plan; records identifying an MCSO language-access liaison or ADA contact; monitoring, assessment, deficiency, and corrective-action records; aggregate records reflecting interpreter-service use; and complaint-tracking records maintained by the central compliance function.

That scope governs how the findings should be read. Where this review reports that something was not established, that category of record was sought. Where a topic fell outside the requests, it is not treated as evidence of a gap in MCSO's system.

The analysis covers MCSO law-enforcement operations involving members of the public. Jail and Corrections Bureau operations are outside the principal scope, except where Jail material appeared in the County's production and bears on the limits of that production.

This review does not treat a written policy or vendor contract as proof that effective communication occurs in any given encounter, and it does not treat the absence of a produced record as proof that the underlying activity never happened. The question is what the record establishes and what remains unverified.

Written Policy Framework

MBGO-093-16, "Communicating with People who are Deaf or Hard of Hearing," is a procedural order rather than a general nondiscrimination statement.

It applies to victims, witnesses, suspects, arrestees, and other individuals encountered by Sheriff's Office personnel. It ties effective communication to operational tasks such as determining what occurred, assessing the urgency and nature of an incident, and carrying out law-enforcement functions.

The order identifies written communication, TTY/TDD, telephone amplification, videotext, video remote interpreting, video relay services, and interpreters as possible communication aids.

Personnel are directed to determine what aid the individual needs. The person's expressed choice receives primary consideration, subject to whether another method is equally effective or whether the requested aid would fundamentally alter the activity or impose an undue financial or administrative burden.

The order also recognizes the limits of simpler methods. Written notes may suffice for shorter or less complex interactions but are not treated as a universal substitute for qualified interpretation. The policy contemplates escalation to a qualified or certified interpreter when the nature, importance, or complexity of the communication requires it. That creates a documented decision framework instead of a default assumption that written notes will always be sufficient.

Interpreter Access Pathways

The production identifies two current outside interpreter resources and an operational routing instruction.

Communication Services, Inc., doing business as Interpretek, provides certified sign-language interpreting under an agreement running from April 1, 2026 through March 31, 2027. The agreement covers criminal investigations, public events, ceremonies, graduations, and other Sheriff's Office activities as needed.

Tellmorr International Translation Services provides on-demand, 24-hour in-person interpreting under an agreement running from October 1, 2025 through September 30, 2026. American Sign Language is expressly included among the covered languages. Tellmorr must supply an interpreter who can respond in person within four hours. The agreement also requires background checks, permits recorded interpretation where legally permissible, provides for transcription on request, and requires interpreter availability for later legal proceedings when necessary.

A Police Bureau roll-call bulletin supplies the activation instruction. It identifies interpreter resources available to personnel, directs members to consider an over-the-phone service before contacting Tellmorr for in-person interpretation, and directs notification of a command officer before using Tellmorr where possible.

Together these records establish a defined interpreter-access system on paper, with named vendors, an activation sequence, and a contractual performance standard. They do not establish how often that system is used or whether the bulletin's sequence is followed in the field.

Timing Standards

MCSO's record contains a measurable response standard, but it governs the vendor rather than the agency. Tellmorr's four-hour in-person response requirement is a contractual performance term, not an interpreter-request standard.

Nothing in the records reviewed defines the period within which a deputy must initiate a request after determining that an interpreter is needed. No maximum response time is established for the other interpreter pathways available to MCSO.

A vendor can satisfy a four-hour response requirement even if the initial request was delayed. Evaluating response performance therefore requires several separate timestamps: when the need became apparent, when the request was initiated, when the vendor received or accepted it, and when the interpreter became available.

MBGO-093-16 captures part of that sequence by requiring personnel to record when an interpreter was called and when the interpreter arrived and departed. The Tellmorr agreement captures another part by requiring the vendor to record request and service times. Those data points are specified in both documents. No record reviewed establishes that anyone aggregates, reviews, or measures them.

Documentation Requirements and the Missing Operational Layer

MCSO's documentation requirements are substantial and specific.

Where an interpreter is used, reports are to identify the interpreter by name or identifying number and employer or organization, and to record call, arrival, and departure times. Written communication exchanged between personnel and Deaf or hard-of-hearing individuals must be preserved. Electronic and digital communications covered by the order are also subject to storage requirements.

Those requirements make the system auditable in principle. A reviewer should be able to establish, in defined cases, that an interpreter was requested, who provided the interpretation, when the request occurred, when assistance arrived, and what was exchanged in writing.

The Tellmorr contract reinforces that trail from the vendor side. The contractor must maintain business records identifying the requester, request and service times, language, interpreter, and associated costs, and must furnish those records to MCSO on request. That provision matters because operational verification does not require reconstructing individual police encounters from case files. Vendor logs alone could show how often in-person interpretation is requested and how quickly it is delivered.

The requirements to create records when the system is used are documented. No corresponding operational records were produced or identified.

Video Remote Interpreting

MBGO-093-16 identifies video remote interpreting (VRI) alongside video relay services, TTY/TDD, amplification, and written communication as possible resources. The County's training materials also discuss VRI as a means of providing rapid interpreter access through devices such as tablets or smartphones.

Field readiness is a separate question, and the production does not resolve it. No records reviewed identify patrol-assigned VRI devices, active accounts or applications, device testing, login procedures, readiness checks, equipment inventories, or any instance of field VRI use by MCSO deputies.

VRI is in the framework. Whether it is available to a deputy at roadside is not established.

Training

The County produced substantial disability-awareness training content.

The New York State Division of Criminal Justice Services Basic Course for Police Officers includes a six-hour "Persons with Disabilities" section covering blindness, deafness, physical disabilities, intellectual disabilities, autism, Alzheimer's disease, and related interactions.

The Deaf and hard-of-hearing portion is comparatively detailed. It addresses communication preferences, sign language, direct communication with the Deaf individual instead of the interpreter, written communication, lip reading, identification of hearing loss, interpreter access, video remote interpreting, traffic encounters, handcuffing, and limits on using family members.

The curriculum references supporting handouts that were also produced, including a Basic Etiquette guide and an American Sign Language alphabet reference.

The production establishes what the curriculum contains. It does not establish who has completed it. No MCSO rosters, sign-in sheets, completion dates, member-level training records, or Deaf and hard-of-hearing refresher schedules were produced, and nothing identifies which current patrol deputies received the material or when.

Governance and County-Level Oversight

MBGO-093-16 assigns each bureau designated personnel to act as liaison between that bureau and Staff Services. That establishes a governance structure at the policy level. The records reviewed do not identify who currently holds that role in the Police Bureau or establish how the liaison interacts with the County's central ADA and language-access function.

Monroe County does maintain a countywide ADA grievance process that applies to MCSO. The reviewed record does not establish a separate MCSO-specific communication-access complaint process, and central complaint-tracking records concerning MCSO communication access were not produced.

FOIL 26-1840 was intended to examine the central County compliance layer, not MCSO case files. The request expressly sought records from the Language Access Compliance Coordinator, Department of Diversity, Equity & Inclusion, or another central County compliance office.

The County's combined response to 26-1840 and 26-1946 materially improved this review. It produced MCSO policies, contracts, bulletins, and training materials. It did not produce the central records sought in 26-1840. The materials reviewed do not identify an MCSO-specific language-access plan, a current central liaison record, periodic MCSO monitoring or assessment records, aggregate interpreter-use reports held centrally, or central complaint-tracking records concerning MCSO communication access.

The production also included substantial Jail Bureau material, though the requests excluded correctional operations.

The County approved the requests "as to existing records" and closed them. It did not provide a category-by-category certification identifying which offices, custodians, or record systems were searched where responsive records were not located.

The finding is not that central oversight of MCSO language access does not exist. It is that such oversight was not established in the records produced.

What the Record Establishes

The materials reviewed establish:

a detailed written Deaf and hard-of-hearing communication policy, MBGO-093-16;
two current outside sign-language interpreter agreements;
a 24-hour in-person interpreting pathway with a contractual four-hour response standard;
a Police Bureau bulletin defining the activation sequence;
interpreter qualification standards;
requirements to document interpreter identity and call, arrival, and departure times;
requirements to preserve written exchanges;
a vendor obligation to maintain and furnish request-and-service records;
disability-awareness and Deaf and hard-of-hearing training curriculum and handouts;
an internal bureau liaison structure; and
a countywide ADA grievance process applicable to MCSO.

The materials reviewed do not establish:

any interpreter request made during a police encounter;
the number of Deaf or hard-of-hearing encounters;
observed interpreter response times or review of those times;
actual field use of Interpretek, Tellmorr, or video remote interpreting;
vendor logs or invoices tied to identified uses;
redacted reports showing how communication assistance was documented;
training completion or refresher records for current deputies;
supervisory review of interpreter-access decisions;
the current identity of the Police Bureau liaison;
central County monitoring of MCSO language-access implementation;
central communication-access complaint tracking; or
VRI device inventory, assignment, or testing.

Most of these categories were expressly sought in the underlying FOIL requests. The remainder are operational records necessary to test whether the written framework can be verified in practice.

Conclusion

MCSO's written interpreter-access framework is developed and its vendor infrastructure is documented and current. The weakness in the record is not policy. It is auditability.

The policy and contracts call for records that could show whether the system works: who requested an interpreter, when, how quickly one arrived, who provided the service, what it cost, and what was exchanged. Those records could answer many of the open questions in this review without reconstructing individual encounters from case files.

They were not produced, and the County's response does not establish whether all of them were searched for. Whether MCSO's interpreter-access system operates as documented remains unestablished in the record.

This review is part of the Monroe County Interpreter Access Audit (MCIAA), an ongoing Transparent Law Enforcement project examining how local agencies document interpreter access for Deaf or hard-of-hearing members of the public.