Related Policies, Procedures, Guidelines, Frameworks

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DGD15-040
Procedure
Language Services - Interpreters
Contents
Purpose....................................................................................................................................... 2
Scope .......................................................................................................................................... 3
Procedure ................................................................................................................................... 4
1.
Determining if an interpreter is needed ............................................................................. 4
2.
Consumer refusal of professional interpreting services ..................................................... 4
3.
Booking a professional, accredited interpreter .................................................................. 5
3.1. Languages other than English (excluding Aboriginal and Torres Strait Islander
languages and Auslan)................................................................................................................ 6
3.1.1
Scheduled interpreter use (e.g., for scheduled appointments) ................................... 6
3.1.2
Unscheduled or emergency interpreter use (including during an appointment) ........ 8
3.1.3
Consumer-initiated TIS telephone interpreting ........................................................... 8
3.1.4
Concerns about TIS interpreting services..................................................................... 8
3.2
Auslan .............................................................................................................................. 9
3.3
Aboriginal and Torres Strait Islander Languages .......................................................... 10
4.
Non-professional interpreters (including multilingual staff and relatives/friends) ......... 10
4.1
Emergencies .................................................................................................................. 11
4.2
Non-emergency and low risk communication situations ............................................. 11
5.
Financial Administration ................................................................................................... 12
6.
Documentation of Interpreter Use ................................................................................... 12
7.
Working with interpreters ................................................................................................ 13
Evaluation ................................................................................................................................. 13
Related Policies, Procedures, Guidelines, Frameworks, Standards and Legislation ................ 14
Definition of Terms................................................................................................................... 15
Search Terms ............................................................................................................................ 15
Attachments ............................................................................................................................. 15
Doc Number
DGD15-040
Version
1
Issued
24 November 2015
Review Date
31 March 17
Area Responsible
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DGD15-040
Purpose
To provide information to ACT Health staff, volunteers and contractors1 about how to use
interpreters, as required by the Policy Language Services (Interpreters, Multilingual Staff and
Translated Material) and related ACT Health Guide to Language Services. This includes
Auslan (Australian Sign Language), Aboriginal and Torres Strait Islander languages, and other
languages other than English.
Providing high quality and safe health services relies on accurate communication between
staff, consumers and their carers and families.2 All ACT Health staff must use professional,
accredited interpreters to communicate with consumers with limited English proficiency
(LEP) or other language needs, including people who use sign language, who may not
otherwise be able to:
 provide necessary information to health professionals and administrative staff;
 understand information and follow directions provided by staff;
 make informed choices about their health care, including giving informed consent;
 access other ACT Health services (such as health promotion and environmental health
services); and/or
 provide feedback or participate in ACT Health consultation processes.
Key principles:
 Interpreting services are free to consumers.
 ACT Health uses professional interpreters accredited by the National Accreditation
Authority for Translators and Interpreters (NAATI).3
(Note: there are many Aboriginal and Torres Strait Islander languages and it may not be
possible to source an accredited interpreter. Contact the relevant Liaison Officer for
assistance, see 3.3.)
Further information explaining the reasons behind actions mandated in this Procedure is
provided in the ACT Health Guide to Language Services available on the intranet.
1
After this, “ACT Health staff” includes volunteers and contractors.
After this, “consumers” includes carers and family members.
3
After this, “accredited” means accredited by NAATI.
2
Doc Number
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Scope
This Procedure relates to interpreter services (services of a person who conveys spoken or
signed messages from one language into another spoken or signed language).
In this Procedure, the term ‘multilingual’ means the ability to speak or sign in a language
other than English, and the term ‘speaking’ includes ‘signing.’
This Procedure does not relate to translation services (services of a person who conveys
written messages from one language into another written language).
For more information, contact the Multicultural Health Policy Unit (MCHPU) on 6205 1011 or
multiculturalhealth@act.gov.au (business hours).
Clinical areas
This Procedure focuses on interpreting in clinical areas and applies to:
 all ACT Health staff who need to communicate with consumers with LEP, including
Visiting Medical Officers;
 ACT Health staff who are receiving the Linguistic Availability/Performance Allowance
(LAPA); and/or
 multilingual ACT Health staff and their managers.
Non-clinical areas
The use of interpreters may also be required in non-clinical areas, such as:
 developing or delivering health promotion initiatives;
 environmental health, food safety and other regulatory activities;
 conducting consumer surveys;
 consulting on policy or service planning; and
 receiving and responding to consumer feedback.
Engaging Canberrans – A guide to community engagement supports the use of professional,
accredited interpreters in such situations (see section 7.14: Engaging with culturally and
linguistically diverse communities).
The procedure for engaging a professional, accredited interpreter is the same for clinical and
non-clinical areas.
Doc Number
DGD15-040
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Review Date
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Procedure
1. Determining if an interpreter is needed
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An interpreter is needed if there is any chance of misunderstanding due to language
differences. Some consumers’ English skills may be reduced in traumatic or
emotional situations.
ACT Health staff must record in ACTPAS whether a consumer needs an interpreter,
and their preferred language. If the information in ACTPAS is incorrect, a staff
member with ACTPAS edit access must correct it as soon as possible.
Staff should not guess what language a consumer speaks based on the country of
birth recorded in ACTPAS, their name, or their appearance (e.g., a person born in
Burma may speak Karen or Mon rather than Burmese).
Consumers may show an ACT Health Interpreter Card which states their preferred
language. Staff can also download the card and give it to a consumer if needed.
Staff can also use the Language Identification Chart to find out which language is
required. This chart includes common languages but is not exhaustive.
If the consumer wishes, they may be accompanied by relatives or friends for support
during a professional interpreter session.
2. Consumer refusal of professional interpreting services
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A consumer may refuse a professional interpreter, and may ask to have a family
member act as an interpreter instead.
Consumers may refuse an interpreter because they are concerned about cost,
confidentiality, or the interpreter’s gender.
Staff should make reasonable attempts (using a family member, multilingual staff or
a telephone interpreter) to understand and address these concerns, and secure the
consumer’s agreement to professional interpreting services.
Staff should explain that:
o the service is free;
o interpreters must maintain confidentiality;
o interpreters are available face-to-face or by telephone (the consumer can remain
anonymous with a telephone interpreter);
o the consumer can choose a male or female interpreter;
o medical interpreting is a specialist skill, and family members may not have the
ability to interpret accurately or objectively on health or medical matters;
o professional interpreters are trained, insured, and bound by a code of ethics;
o an interpreter will assist in providing the best possible and safest care; and
o it is ACT Health policy to use professional interpreters.
For clinical services, if a consumer refuses professional interpreting services and/or
decides to use a family member to interpret, staff must document this in the clinical
record.
Doc Number
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3. Booking a professional, accredited interpreter
START HERE
For more information, see
the section number in bold
NO
Interpreter Required?
Proceed
What kind of interpreter?
3.3
3.1
3.2
Auslan
(Sign language)
Language
other than English
Aboriginal or
Torres Strait Islander Language
Emergency?
Emergency?
After-hours?
3.1.2
YES
NO
YES
NO
3.1.1
Contact TIS
Is interpreter
immediately
available
(phone or on-site)?
YES
On-site interpreter
required?
NO
YES
Proceed
Reschedule
Contact relevant
Liaison Officer
Contact after-hours
Social Worker
Contact NICSS
or
SLC Emergency
Service
Contact NICSS
Is interpreter
immediately
available?
NO
YES
YES
NO
NO
3.1
YES
Provide critical care
and engage
TIS interpreter ASAP
YES
Contact TIS
Is on-site interpreter
available?
Bilingual staff
member available?
NO
3.1
YES
Contact TIS
Is phone interpreter
available?
NO
Relative or friend
(over 18) available?
Phone Numbers
TIS
131 450
ATIS Voice
1800 131 450
NICSS
1800 246 945
SLC Emergency Service
0412 422 059
Aboriginal and Torres Strait Islander Liaison Officers
Alcohol and Drug
6207 9977 or 6205 8387
Calvary Hospital
6264 7097
Canberra Hospital
6244 2316
After-hours Social Worker
TCH Switchboard 6244 2222
Doc Number
DGD15-040
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Proceed
YES
Reschedule
NO
If a TIS interpreter is not available, contact
MCHPU (business hours 6205 1011) or visit
the NAATI website (See Section 3.1) for
alternatives.
Interpreting services are free to consumers.
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3.1. Languages other than English (excluding Aboriginal and Torres Strait Islander
languages and Auslan)
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The Translating and Interpreting Service (TIS), operated by the Department of
Immigration and Border Control, is the preferred provider for ACT Health.
To access TIS services you will need your work area’s TIS Client Code. Your Client
Code starts with the letter ‘C’ followed by six digits (e.g., C123456). Your Client
Code should be available:
o on a poster displayed in your administration area;
o from your area’s administration staff;
o on the Intranet at Business Support/Multicultural Health; or
o from the MCHPU on 6205 1011 or multiculturalhealth@act.gov.au (business
hours).
Contact the MCHPU on 6205 1011 or multiculturalhealth@act.gov.au (business
hours) if you have any problems booking an interpreter through TIS, or check the
NAATI website to find an alternative accredited interpreter.
3.1.1 Scheduled interpreter use (e.g., for scheduled appointments)
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Doc Number
DGD15-040
Wherever possible, staff should check if an interpreter is needed and book an
interpreter if necessary before a scheduled appointment.
If an appointment with a booked interpreter is changed or cancelled, staff must
notify TIS as soon as possible to minimise late cancellation charges.
Often, telephone interpreting is convenient, flexible and cost-effective.
Telephone interpreting provides access to more languages and may sometimes
be the only option.
Staff should use a telephone interpreter unless using an on-site interpreter is
likely to particularly help the consumer (e.g., in sensitive or complex situations,
such as mental health assessments or obtaining informed consent), and/or the
consumer requests an on-site interpreter.
Staff should not assume that all consumers prefer on-site interpreters. Some
consumers may prefer a telephone interpreter, especially where they wish to
remain anonymous (such as accessing sexual health services), and/or where the
consumer’s preferred language is only spoken by a small local community and
they are likely to know the interpreter.
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3.1.1.1.
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3.1.1.2.
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Booking a TIS telephone interpreter in advance
Complete the Interpreter Booking Form at
https://www.tisnational.gov.au/Agencies/Forms-for-agencies/NewJob-booking-form. You will need your area’s TIS Client Code.
TIS will allocate an interpreter and email a confirmation with a job
number.
Just before the start time of the pre-booked job:
o Telephone TIS on 1300 655 070.
o Quote the pre-booked job number and TIS will connect you
with the interpreter.
Booking a TIS on-site interpreter in advance
Bookings for on-site interpreters must be made through TIS Online at:
https://tisonline.tisnational.gov.au/Login
For access to TIS Online, contact your TIS Account Administrator or the
MCHPU on 6205 1011 or multiculturalhealth@act.gov.au (business
hours).
Access can be made available to individuals using their ACT
Government email address, or to a group of staff sharing a generic
email address (e.g. genetics@act.gov.au).
When granted access, you will receive an email from TIS giving you
instructions as to how to complete the process and generate a
password.
Log in to TIS Online at https://tisonline.tisnational.gov.au/ with your:
o Email address (individual or group);
o Client ID (this is the same as your area’s TIS Client Code); and
o The password you generated as an individual or for a group
when completing the access process.
Once you have logged in to TIS Online, click on the “Create new job”
button at the top of the screen, and fill out the required information.
Information about booked jobs can be found under “My jobs
summary” at the top left of the screen.
Support for TIS Online is available on 1300 655 082 or
tis@border.gov.au (business hours) or see A guide to TIS Online for
agencies.
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3.1.2 Unscheduled or emergency interpreter use (including during an
appointment)
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Staff can immediately access a telephone interpreter through TIS ATIS Voice.
o As of 1 September 2015, ATIS Voice is only available in the following
languages: Arabic (not including Sudanese Arabic), Bosnian, Cantonese,
Croatian, Dari, Greek, Italian, Japanese, Khmer, Korean, Mandarin, Persian
(Farsi), Russian, Serbian, Somali, Spanish, Turkish and Vietnamese.
o For a current list, check the TIS website.
o You will need your work area’s ATIS Voice Account Number, and ATIS
Voice Access Code (these are different from the TIS Client Code). These
should be available:
 on a poster displayed in your administration area;
 from your area’s administration staff;
 on the Intranet at Business Support/Multicultural Health; or
 from the MCHPU on 6205 1011 or multiculturalhealth@act.gov.au
(business hours).
Phone ATIS Voice on 1800 131 450 and follow the prompts.
For immediate telephone interpreting in languages not covered by ATIS Voice,
phone TIS on 131 450. You will need your work area’s TIS Client Code (see 3.1).
3.1.3 Consumer-initiated TIS telephone interpreting
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Consumers are able to use a telephone interpreter to contact ACT Health by
calling 131 450.
TIS will then call the relevant area of ACT Health and ask if the charge for the
interpreting service will be accepted.
Work areas must state that the charge will be accepted and provide the relevant
TIS Client Code.
TIS will then connect the consumer and the interpreter in a three-way phone call.
3.1.4 Concerns about TIS interpreting services
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Doc Number
DGD15-040
Contact the MCHPU for any concerns about TIS interpreting services (including
accessibility, reliability and/or quality) on 6205 1011 or
multiculturalhealth@act.gov.au (business hours).
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3.2 Auslan
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Staff should use on-site Auslan interpreters wherever possible.
Staff may also use Auslan video remote interpreting (VRI), if the work area has
access to an appropriate device (e.g., tablet or smartphone); Skype, Facetime or
a similar video call program; and an internet connection. Consumers may wish to
bring in their own device for VRI but this should not be expected.
The National Interpreting and Communication Services (NICSS) provides on-site
and VRI Auslan interpreters.
o Staff can book an interpreter by calling 1800 246 945 from 8am to 9pm
weekdays and 8am to 2pm on Saturdays (including all public holidays
except national public holidays).
o NICSS requires a client code to book an interpreter. NICSS will create a
new client code for ACT Health areas that have not used the service
before (there is no single ACT Health client code).
For emergency situations outside these hours, Sign Language Communications
(SLC), run by the Deaf Society of NSW, provides a 24 Hour Emergency Interpreter
Service in the ACT.
o Call or SMS 0412 422 059 to contact the Emergency Interpreter Service.
o This service should not be used in non-emergency situations.
o SLC does not require a client code to make a booking, but will send an
invoice to a nominated email address after the job.
There are many options for communicating with people who are D/deaf, hard of
hearing, or who have other language and communication needs. For example,
the National Relay Service offers internet relay, captioned relay, Speak and
Listen, Type and Listen, SMS relay, and other services.
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3.3 Aboriginal and Torres Strait Islander Languages
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There are very many different Aboriginal and Torres Strait Islander languages. It may
not be possible to identify an accredited interpreter in the required language.
Contact the relevant Aboriginal and Torres Strait Islander Liaison Officer for
assistance:
o Alcohol and Drug Aboriginal and Torres Strait Islander Liaison Officer
(6207 9977 or 6205 8387)
o Calvary Aboriginal and Torres Strait Islander Liaison Officer
(6264 7097)
o Canberra Hospital Aboriginal and Torres Strait Islander Liaison Service
(6244 2316)
o Mental Health Aboriginal and Torres Strait Islander Liaison Officer
(Gugan Gulwan Youth Aboriginal Corporation) (6296 8900)
For emergency situations outside business hours, call the Canberra Hospital
Switchboard on 6244 2222 and ask for the after-hours social worker.
4. Non-professional interpreters (including multilingual staff and relatives/friends)
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Multilingual staff and relatives/friends can help to communicate with consumers with
LEP, but they must not replace professional, accredited interpreters, particularly in
situations which may be a risk for consumers and/or ACT Health. Professional,
accredited interpreters must be used wherever possible, due to the risks involved in
using non-professional interpreters. Interpreting is a professional skill and professional
interpreters are trained, insured, and bound by a code of ethics.
In situations where a professional interpreter is needed but not immediately available,
such as emergencies, a staff member (with the consent of their manager) or a
relative/friend who speaks the required language and who agrees may facilitate urgent
communication, until a professional interpreter can be used (see 4.1 below).
Multilingual staff and the consumer’s family or friends may also provide language
assistance to consumers or staff to fill communication gaps, in situations where basic
language skills are sufficient and the risk to the consumer and/or ACT Health from
miscommunication is low (see 4.2 below).
People, Services and Strategy Branch will maintain a list of languages spoken by staff
members and their LAPA status which will be available on the intranet.
Note: Children under the age of 18 must never be used as interpreters, including in
emergency situations.
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4.1. Emergencies
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In an emergency where interpreting is required immediately but a professional,
accredited interpreter is not available, staff should use the following options (in order
of priority):
1. Multilingual ACT Health staff receiving the LAPA
2. Other multilingual ACT Health staff
The MHCPU will maintain a list on the intranet of staff willing to self identify.
3. Adult relatives or friends of the consumer.
Follow these steps to use multilingual staff to interpret in an emergency:
o Identify an ACT Health staff member receiving the LAPA who speaks the
required language and may be able to assist. If you cannot find an appropriate
person receiving the LAPA, you can try other multilingual staff.
o Contact the manager of the identified staff member to seek their agreement.
o If the manager agrees, contact the identified staff member.
o A staff member receiving LAPA should generally agree to interpret in
emergency situations. Staff members may reasonably decline in some
situations, such as potentially traumatic situations, or if they know the
consumer.
o A staff member not receiving LAPA may decline to provide interpreting
services in emergency situations, even if their manager agrees.
o Staff should offer support (e.g., the Employee Assistance Program) to
multilingual staff used as interpreters in emergency situations, regardless of
LAPA status.
Staff may proceed with emergency treatment based on information from a
non-professional interpreter but they must use a professional, accredited interpreter
to check this information as soon as possible.
Staff must document non-professional interpreter use in emergency situations on the
consumer’s clinical record and in RiskMan (see 6 below).
If a non-professional interpreter is unavailable, staff may proceed with emergency
treatment and must record the unavailability of an interpreter on the consumer’s
clinical record and in Riskman (see 6 below).
4.2. Non-emergency and low risk communication situations
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Multilingual staff and relatives/friends of a consumer may interpret in low risk
situations, such as:
o making an appointment;
o giving directions within an ACT Health facility; or
o giving information about visiting hours.
Staff should use the following options (in order of priority):
1. Multilingual ACT Health staff receiving the LAPA
2. Other multilingual ACT Health staff
The MHCPU will maintain a list on the intranet of staff willing to self identify.
3. Adult relatives or friends of the consumer
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Follow these steps to use multilingual staff to interpret in a low risk situation:
o Identify an ACT Health staff member receiving LAPA who speaks the required
language and may be able to assist. If you cannot find an appropriate person
receiving the LAPA, you can try other multilingual staff.
o Contact the manager of the identified staff member to seek their agreement.
o If the manager agrees, contact the identified staff member.
o A staff member receiving LAPA should generally agree to interpret in low risk
situations.
o A staff member not receiving LAPA may decline to provide interpreting
services in low-risk situations, even if their manager agrees.
5. Financial Administration
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ACT Health staff must provide interpreting services to consumers at no cost.
Staff must use interpreters when needed regardless of the cost.
For Canberra Hospital and Health Services (CHHS), interpreter costs are centralised.
CHHS Divisions/Branches/Work Areas are not required to budget or pay for
interpreting services. Staff should follow the rules provided by the Business
Management and Efficiency Unit to process invoices for interpreter services. Invoices
should be coded to Cost Centre 64421, Account Code 712107
Staff from other divisions (such as Strategy and Corporate, Population Health, and
Health Infrastructure and Planning) must code interpreter related expenses to their
appropriate internal Cost Centre and Account Code 712107.
6. Documentation of Interpreter Use
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People from culturally and linguistically diverse (CALD) backgrounds and/or with LEP
are at greater risk of adverse incidents from health care, often due to communication
issues.
If staff do not use professional, accredited interpreters when required, there are risks
for consumers and for ACT Health, including legal action.
Staff must document the following information on consumer clinical records,
including consent forms:
o each occasion of use of a professional, accredited interpreter;
o each occasion of use of a non-professional interpreter (including multilingual
staff, and relatives/friends of the consumer);
o consumer refusal of interpreting services; and
o reasons for continuing the appointment/treatment/procedure without
interpreting services.
Staff must also document the use of a non-professional interpreter in clinical
situations in Riskman.
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7. Working with interpreters
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Staff should hold interpreting sessions in a private, quiet area, if possible.
Training on working with interpreters is provided through Staff Development Unit.
For further information see:
o ACT Health Guide to Language Services
o the intranet (Business Support/Multicultural Health)
o TIS (http://www.tisnational.gov.au/Agencies/Help-using-TIS-Nationalservices/Working-with-TIS-National-interpreters)
Evaluation
Outcome Measures
 Number of times professional interpreters have been engaged.
 Type of interpreting service used (telephone or on-site).
 Languages for which professional interpreters have been engaged.
 Quarterly expenditure on interpreter services.
 Number of times interpreters have been requested but are not available
(including language requested).
 Number of times interpreters have been requested and subsequently declined by a
consumer (including reason for declining).
 Compliance with requirement to document interpreter use.
 Number of staff receiving LAPA, number of times a non-professional interpreting
service has been provided, and in which languages.
 Number of staff who have completed training in working with interpreters.
Method
The following data will be collected by MCHPU and reported regularly to the Executive
Council, the ACT Health Annual Report and the biennial Chief Health Officer’s Report. Deputy
Directors-General will also be provided with summary reports for distribution within
Divisions.
 Interpreter usage (data provided quarterly/annually by TIS/Auslan interpreter
provider).
 Audits of interpreter use and documentation (in conjunction with Health Care
Improvement Division).
 LAPA uptake (data provided biannually by People, Strategy and Services Branch).
 Routine ACT Health service data collection (including ACTPAS) on CALD consumers to
support needs analysis, i.e., main language spoken at home, English proficiency,
country of birth.
 Data from Capabiliti about staff undertaking relevant training.
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Related Policies, Procedures, Guidelines, Frameworks, Standards and
Legislation
Policies
 Australian Capital Territory Languages Policy Many Voices: 2012-16
 ACT Health Policy: Language Services (Interpreters, Multilingual Staff and Translated
Materials
Procedures
 Canberra Hospital and Health Services, Clinical Procedures:
o Consent and Treatment
o Clinical Handover
o Patient Identification and Procedure Matching
Frameworks
 Australian Safety and Quality Framework for Health Care
 Australian Charter of Healthcare Rights
 Australian Capital Territory Multicultural Strategy 2010-2013
(next version to be developed in 2015)
 Towards Culturally Appropriate and Inclusive Services, a Co-ordinating Framework:
ACT Health (2014-2018)
 ACT Health Guide to Language Services
Standards
 National Safety and Quality Health Service (NSQHS) Standards
o Standard 1: Governance for Safety and Quality in Health Service Organisations
o Standard 2: Partnering with Consumers
o Standard 3: Preventing and Controlling Healthcare Associated Infections
o Standard 4: Medication Safety
o Standard 5: Patient Identification and Procedure Matching
o Standard 6: Clinical Handover
o Standard 7: Blood and Blood Products
o Standard 8: Preventing and Managing Pressure Injuries
o Standard 9: Recognising and Responding to Clinical Deterioration in Acute Care
o Standard 10: Preventing Falls and Harm from Falls
 National Standards for Mental Health Services 2010
o Standard 4: Diversity Responsiveness

Australian Bureau of Statistics – Standards for Statistics on Cultural and Language
Diversity 1999.
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Legislation
 Mental Health (Treatment and Care) Act 1994
 Work Health and Safety Act 2011
 Human Rights Act 2004
 Discrimination Act 1991
 Health Act 1993
Definition of Terms
Auslan
The language of the Australian Deaf community. Auslan is a unique sign
language.
CALD
Culturally and linguistically diverse.
Consumer
Anyone who uses, has used or may use any ACT Health service, including
carers and family members.
Interpreter
A person who conveys oral or sign messages, concepts and ideas from one
language into another language (including sign languages), with a high degree
of accuracy, completeness, objectivity and sensitivity to the cultures
associated with the languages of expertise. The interpreter is responsible for
the communication process between the two parties and not for the
information provided.
LEP
Limited English proficiency.
LOTE
Language(s) other than English.
Search Terms
Interpreter; interpreting; language; language services; Translating and Interpreting Service;
TIS; Auslan; sign language; Aboriginal and Torres Strait Islander languages; culturally and
linguistically diverse; CALD; limited English proficiency; LEP;.
Attachments
o ACT Health Policy Language Services (Interpreters, Multilingual Staff and Translated
Materials)
Disclaimer: This document has been developed by ACT Health specifically for its own use. Use of this document
and any reliance on the information contained therein by any third party is at his or her own risk and ACT Health
assumes no responsibility whatsoever.
Date Amended
Eg: 17 August 2014
Doc Number
DGD15-040
Version
1
Section Amended
Section 1
Issued
24 November 2015
Review Date
31 March 17
Approved By
ED/CHHSPC Chair
Area Responsible
PGR
Page
15 of 15
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