The federal definition of LEP is intentionally broad. Anyone who self-identifies as having limited English proficiency is LEP for purposes of language-access obligations. There is no test, no threshold, no documentation requirement, and federal agencies have been explicit that organizations cannot demand LEP patients prove their LEP status.
In Minnesota specifically, the LEP population is large and diverse. Census ACS data identifies over 350,000 LEP residents statewide, speaking more than 100 languages. The top spoken languages are Spanish, Hmong, Somali, Karen, Vietnamese, Amharic, Oromo, Russian, Mandarin, and Arabic, though distribution varies significantly by region (Twin Cities metro, Rochester, Greater Minnesota all have distinct demographic profiles).
LEP status overlaps with but does not equal national origin. A US-born citizen who grew up in a Hmong-speaking household and has limited English literacy is LEP. A naturalized citizen who speaks fluent English but prefers their first language for medical discussions is LEP. The category is functional, not legal.