Transcript JCAH-O Ethics Standards

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-BC
Vice President of Patient Services/Chief Nursing Officer
Akron, OH
The Joint Commission Ethics Standard
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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)
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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:
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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
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The Limited English Proficiency (LEP) population
in the CHMCA service area that represents 5% or
1,000 individuals in the area is Spanish.
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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
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Vital document: A document, paper or electronic,
that contains information that is critical for accessing
the provider/agency services and/or benefits.
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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.”
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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
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Estimate of costs for translation to Spanish is
~$2600 based on $40/200 word page.
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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
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Estimate of costs for translation to Spanish is
~ $40,000 based on $40/200 word page.
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Patient Menus $300
Patient education materials for home-going
instructions ~$40,000
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Care Information Sheets (460) ~ $20,000
Tips To Grow By (230) ~20,000
Interpreter Services
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Other LEP populations served:
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Hearing impaired and deaf populations
Limited English Proficient populations
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Hispanic Languages
Asian Languages: Mandarin Chinese, Vietnamese,
Korean, Karen (Myanmar)
Arabic Languages
Indian Languages
African Languages: Somali
Interpreter Services: Language Banks
Akron Children’s Hospital
2006
2007
(Annualized)
Billed Interpreter
Encounters
91
267
2008
2008
(Through 10-15)
(Annualized)
386
440
International Institute: 90% in 2008
Interpreter Bills
$10,815 $31,196 $56,309 $64,353
Language Bank Interpreter Bills
60000
50000
40000
30000
20000
10000
0
2006
2007
2008
Dollars
Interpreter Services by Language
140
120
100
80
60
40
20
0
Karen
Burmese
Spanish
Albanian
Nepali
Encounters
Chinese
Russian
Other
Interpreter Services: Language Line
Akron Children’s Hospital
2006
2007
2008
(through September)
Billed Interpreter Encounters 808
Interpreter Bills
872
844
$22297 $23604 $31255
Interpreter Services: Sign Interpreters
GreenLeaf Family Services
2006
2007
2008
(through October)
Billed Interpreter Encounters
Interpreter Bills
54
84
76
$3,446
$6,262
$4,848
2008 Projections
Interpreter Services
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Language Line Interpreters
Language Bank Interpreters
Sign Interpreters
- $41,673
- $64,353
- $ 6,000
Interpreter charges Total
- $112,026
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Models for Provision of Coordination
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Designated hospital position
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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
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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
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Develop language assistance plan and measures
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Coordinate qualified interpreter services
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Resource to direct care staff serving LEP populations
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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.
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
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Position costs if hired by CHMCA
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(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
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Assures compliance with Federal and Joint
Commission standards prevents costly
litigation.
Opportunities to control interpreter costs:
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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
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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
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Funds for document translation
Coordinator position and location within the
organization
Operating budget for Interpretive Services