Interpretive Services

Legal directives and accreditations standards for culturally competent healthcare

The following resource was submitted with the purpose of distributing to AONE members as part of the AONE Diversity in Health Care Organizations Toolkit

Submitted by: Akron Children’s Hospital Contact person: Lisa Aurilio, MSN, RN, NEA-BCVice President of Patient Services/Chief Nursing OfficerAkron, OH

The Joint Commission Ethics Standard RI 2.100 – The organization respects the

patient’s right to and need for effective communication.

EP 3: The hospital provides interpretation (including translation) services as necessary.

Limited English Proficiency (LEP) Those patients/families who cannot speak,

read, write or understand the English language at a level that permits them to interact effectively with program service providers.

U.S. Department of Justice Office of Civil Rights Safe Harbor

Guidelines to ensure access to written materials and documents for LEP patients served by federally funded health care organizations in order to comply with Title VI of the Civil Rights Act of 1964. Thresholds:

Written translations of agency vital documents provided for each language group that constitutes at least 5% or 1,000 individuals, whichever is less, of the population of persons eligible to be served or encountered by programs in the service area.

If < 50 persons in a language group, the agency provides written notice in the primary language of the LEP group of their right to oral interpretation of vital document written materials, free of cost.

LEP regulations: Prohibited Practices Office of Civil Rights provides the following as examples of

practices which may violate Title VI: Providing services to LEP persons that are more limited in scope or

are lower in quality, Subjecting LEP persons to unreasonable delays in the delivery of

services, Limiting participation in a program or activity on the basis of English

proficiency, Providing services to LEP persons that are not as effective as those

provided to those who are proficient in English, or Failing to inform LEP persons of the right to receive free interpreter

services and/or requiring LEP persons to provide their own interpreter.

Safe Harbor Threshold and Service Areas

The Limited English Proficiency (LEP) population in the CHMCA service area that represents 5% or 1,000 individuals in the area is Spanish. U.S. Census Data (2006) Spanish speaking 5 years old +

Summit County 7,221 Akron 3,906 Total population 512,567 Mahoning County 6,566

Urgent Need for CHMCA:Spanish translation of vital documents Vital document: A document, paper or electronic,

that contains information that is critical for accessing the provider/agency services and/or benefits. U.S. Office of Civil Rights describes vital documents as

"applications, consent forms, letters containing eligibility or participation information, notices pertaining to services or benefits, documents that require a response from beneficiaries, and advise of free language assistance, and the like.”

U.S. Department of Health and Human Services, Office of Civil Rights. Policy Guidance. Title VI Prohibition Against National Origin Discrimination As It Affects Persons With Limited English Proficiency. September 1, 2000.

Translation of Vital Documents Estimate of costs for translation to Spanish is

~$2600 based on $40/200 word page. Consent and Complaint Forms $480 Free Language Assistance $40 Patient Rights and Responsibilities $40 Intake forms that may have important

consequences $2000

Translation of Non-vital Documents Estimate of costs for translation to Spanish is

~ $40,000 based on $40/200 word page. Patient Menus $300 Patient education materials for home-going

instructions ~$40,000 Care Information Sheets (460) ~ $20,000 Tips To Grow By (230) ~20,000

Interpreter Services Other LEP populations served:

Hearing impaired and deaf populations Limited English Proficient populations

Hispanic Languages Asian Languages: Mandarin Chinese, Vietnamese,

Korean, Karen (Myanmar) Arabic Languages Indian Languages African Languages: Somali

Interpreter Services: Language BanksAkron Children’s Hospital

2006(Annualized)

2007 2008(Through 10-15)

2008(Annualized)

Billed Interpreter EncountersInternational Institute: 90% in 2008

91 267 386 440

Interpreter Bills $10,815 $31,196 $56,309 $64,353

Language Bank Interpreter Bills

0

10000

20000

30000

40000

50000

60000

2006 2007 2008

Dollars

Interpreter Services by Language

0

20

40

60

80

100

120

140

Karen Burmese Spanish Albanian Nepali Chinese Russian Other

Encounters

Interpreter Services: Language Line Akron Children’s Hospital

2006 2007 2008(through September)

Billed Interpreter Encounters 808 872 844

Interpreter Bills $22297 $23604 $31255

Interpreter Services: Sign InterpretersGreenLeaf Family Services

2006 2007 2008(through October)

Billed Interpreter Encounters 54 84 76

Interpreter Bills $3,446 $6,262 $4,848

2008 Projections Interpreter Services

Language Line Interpreters - $41,673 Language Bank Interpreters - $64,353 Sign Interpreters - $ 6,000

Interpreter charges Total - $112,026

Models for Provision of Coordination Designated hospital position

Combine Customer Service, Family Centered Care and Interpretive Services

Patient Family Education Community Outreach Social Work Department

Contract with outside group(s) such as International Institute of Akron or AT&T Language Line for service coordination.

Current Needs Comply with The Joint Commission & Safe Harbor provisions:

Translation of existing and new vital documents Maintenance of translated vital documents Written notice of language access rights Technologies to assist with all LEP populations Interpreter services for LEP and deaf/hearing impaired

populations A telephone voice mail menu in Spanish Staff education on accessing resources

Proposal: Coordinator Interpretive Services Develop language assistance plan and measures

Coordinate qualified interpreter services Interpreters proficient in English and the second language;

knowledge in both languages of relevant specialized terms or concepts; completion of training on the skills and ethics of interpretation, awareness of relevant cultural issues.

Resource to direct care staff serving LEP populations Education and consultation to promote culturally competent care in

compliance with federal regulations such as Safe Harbor provisions and regulatory standards such as The Joint Commission.

Monitor and update the language assistance plan

Finances Necessary Position costs if hired by CHMCA

(1 FTE = $60-$80 K plus fringes) Ongoing costs of contracted document

translation and interpretive services State-of-the-art medical interpretation

technology program

Financial Reasons to Hire a Coordinator Now Assures compliance with Federal and Joint

Commission standards prevents costly litigation.

Opportunities to control interpreter costs: Encourage use of Language Line for less critical

needs (dual hand-set phones) Educate staff to reduce “downtime” for live

interpreters Require authorization from interpreter services

Financial Reasons for Coordinator Explore alternative companies – telephone/video

interpreter services Hire or contract for high use language interpreters

with an organization-wide focus Require bilingual coordinator who can provide

limited interpreter and translation services Improve data tracking and monitoring Explore grants and collaborative efforts

Administrative Decisions Needed Funds for document translation Coordinator position and location within the

organization Operating budget for Interpretive Services