PARTNERSHIP HEALTHPLAN OF CALIFORNIA
POLICY / PROCEDURE
Policy/Procedure Number: MP 302
Lead Department: Member Services
External Policy
Policy/Procedure Title: Cultural and Linguistic Services
Internal Policy
Next Review Date: 11/18/2016
Original Date: 02/26/1999
Last Review Date: 11/18/2015
Applies to:
Medi-Cal
Healthy Kids
Employees
Reviewing
Entities:
IQI
P&T
QUAC
OPERATIONS
EXECUTIVE
COMPLIANCE
DEPARTMENT
Approving
Entities:
BOARD
COMPLIANCE
FINANCE
PAC
CEO
COO
CREDENTIALING
Approval Signature: Debbie Shafer
DEPT. DIRECTOR/OFFICER
Approval Date: 11/18/2015
I.
RELATED POLICIES:
A. MMCD Policy Letter 99-04
B. MMCD Policy Letter 99-03
C. PHC HR Policy #509
D. DHCS MMCD APL 11-010
II.
IMPACTED DEPTS.: N/A
III.
DEFINITIONS:
A. CAC – Consumer Advisory Committee
B. DHCS – Department of Health Care Services
C. EOC – Evidence of Coverage
D. ICE – Industry Collaboration Effort (ICE)
E. IQI – Internal Quality Improvement
F. LEP – Limited English Proficiency
G. MMCD – Medi-Cal Managed Care Division
H. OHC – Other Health Coverage
I. SPD – Seniors and Persons with Disabilities
J. TJC – The Joint Commission
IV.
ATTACHMENTS:
A. Interpreting Services Log
B. List of vendors who provide Interpreting Services
V.
PURPOSE:
To ensure effective communication regarding treatment, diagnosis, medical history and health education by
providing cultural, linguistic, and sensory appropriate services to Members, taking into consideration
Members’ beliefs, traditions, customs, and individual differences.
VI.
POLICY / PROCEDURE:
A. Demographic Profile
1. Demographic profiles of PHC’s membership are reviewed annually to determine threshold
languages.
2. Medi-Cal - The language code provided on the 834 file is used to determine primary languages.
3. Healthy Kids and Medicare – Reports are generated internally that capture the language code that is
Page 1 of 10
Policy/Procedure Number: MP 302
Lead Department: Member Services
Policy/Procedure Title: Cultural and Linguistic Services
☒External Policy
☐Internal Policy
Original Date: 02/26/1999
Applies to:
☒ Medi-Cal
Next Review Date: 11/18/2016Last Review Date: 11/18/2015
☒ Healthy Kids
☐ Employees
entered when processing the member’s enrollment application.
4. In accordance with PHC Policy ADM-02, Confidentiality, this information is collected, summarized
and documented in a manner that enables PHC to maintain confidentiality of personal information
and to disclose the information to Department of Health Care Services (DHCS) on request for
regulatory purposes and to contracting providers on request for lawful purposes, including language
assistance purposes and health care quality improvement purposes.
B. Identification of Threshold Languages
1. Medicare - Any language representing 10% or greater of the total member population.
2. Medi-Cal and Healthy Kids– A population group of mandatory Medi-Cal beneficiaries residing in
the service area who indicate their primary language as other than English, and that meet a numeric
threshold of 3,000 or five percent (5%) of the beneficiary population whichever is lower; and A
population group of mandatory Medi-Cal beneficiaries residing in the MCP’s service area who
indicate their primary language as other than English and who meet the concentration standards of
1,000 in a single zip code or 1,500 in two contiguous zip codes. (MMCD APL 14-008)
C. Notification to Members of the Availability of Linguistic Services (All Product Lines)
1. PHC notifies members of the availability of these services as follows:
a. PHC Member Handbook/Evidence of Coverage (EOC) – Sent with the New Member Packet.
b. Notices in Provider Offices – Signs are provided in threshold languages to offices during new
provider site visits and annually thereafter by Provider Relations staff.
c. PHC Website – Information provided in member and provider sections of the PHC website,
Language Assistance
d. Newsletter – Published in the Member and Provider newsletters.
e. Information is published in the provider and practitioner manuals.
D. Staff Training (All Product Lines)
1. PHC provides an annual training to all staff that has direct contact with members. This training
includes the following topics:
a. Review of PHC Cultural and Linguistic Services Policy
b. Understanding the needs of Limited English Proficiency (LEP) members
c. Understanding cultural differences of LEP members
d. Interpreter Services Criteria
e. How to access interpreter services
f. How to effectively use and interact with available interpretation services
g. Seniors and Persons with Disabilities sensitivity awareness training (State Approved)
E. Services Provide
1. Language Line Services (All Product Lines) - PHC contracts with Language Line services. This
service provides real time interpretation services and is available on a 24-hour basis. The Language
Line is used by PHC staff for languages not spoken by staff for LEP members. This service is also
available to contracted providers at key points of contact, including pharmacies.
2. Written Materials (All Product Lines) - All written member materials, including those required by
the DHCS as outlined in Medi-Cal Managed Care Division (MMCD) Policy Letter 99-04 are
translated by a certified translator in threshold languages. These materials are also available in audio,
large print, electronically such as CD or diskettes for members with hearing and/or visual
disabilities. Braille versions are available for members with hearing and visual disabilities. Members
can make a standing request to receive all informing materials in the specific format. This is
accomplished by coding through the PHC IT Department.
3. As outlined in the DHCS contract PHC shall distribute this member information no later than seven
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Policy/Procedure Number: MP 302
Lead Department: Member Services
Policy/Procedure Title: Cultural and Linguistic Services
☒External Policy
☐Internal Policy
Original Date: 02/26/1999
☒ Medi-Cal
Applies to:
4.
5.
6.
7.
8.
9.
10.
11.
12.
Next Review Date: 11/18/2016Last Review Date: 11/18/2015
☒ Healthy Kids
☐ Employees
(7) calendar days following notification of Enrollment. PHC shall also distribute this member
information annually to each Member or family unit.
To ensure the quality of written translation, PHC conducts testing for bilingual staff to qualify to
review and approve documents that have been translated by a contracted vendor. As required in the
DHCS contract, PHC shall ensure that all written Member information is provided to Members at a
sixth grade reading level or as determined appropriate through PHC’s group needs assessment and
approved by DHCS. The written Member information shall ensure the Member’s understanding of
the health plan Covered Services processes and ensure the Member’s ability to make informed
health decisions.
In accordance with MMCD Policy Letter 99-03, the member material must include information
regarding the member’s right to: (a. – d. applies to Medi-Cal Only)
Interpreter services at no charge when accessing health care.
a. Not use family members as interpreters, unless specifically requested by the member.
b. Request face-to-face or telephone interpreter services during discussion of complex medical
information such as diagnoses of complex medical conditions and accompanying proposed
treatment options.
c. Receive documents translated into threshold languages (Refer to Translation of Written
Informing Materials, MMCD Policy Letter 99-04).
d. File grievances or complaints if linguistic needs are not met.
Appeals and Complaints – (All Product Lines)
a. The EOC provides a detailed summary of the process of filing a complaint or appeal. In addition
to this, PHC:
1) Includes an annual Member Newsletter article advising member to contact the Member
Services Department to file a complaint or appeal.
2) Provides complaint and appeal forms in all threshold languages on the PHC website.
3) Maintains Grievance Policies that instruct staff and providers of the requirement of
providing members with appropriate complaint and appeal forms.
4) Conducts on-site audits at Provider sites to ensure that appropriate complaint and appeal
forms are available to members in all threshold languages.
Face-to-Face Medical Interpreter Services (All Product Lines) – LEP members are entitled to
language or sign language interpreters when accessing medically necessary health care services.
Refer to the section of this policy titled Criteria and Authorization Requirements for Interpreting
Services. PHC is not required to provide face-to-face interpreter services to a member whose
provider is willing to provide an on-site interpreter.
Inpatient and Outpatient Hospital Services (All Product Lines) – The Joint Commission (TJC)
requires these services be available at hospitals. It is the responsibility of hospitals to arrange for and
provide these services. Hospitals are also required to provide appropriate services for hearing and
visually impaired patients. If a hospital does not meet its obligation of providing interpretation
services, PHC will arrange for the service to be provided.
Under no circumstances will PHC reimburse providers who chose to provide face-to-face interpreter
services or services for the hearing or visually impaired without making the arrangements for the
provision of services through PHC’s Member Services Department
TDD and California Relay Service (All Product Lines) – These services are available to hearingimpaired members.
Primary Care Assignment (All Product Lines) – To assist all LEP members choose a primary care
provider, the languages spoken at each Provider office are published in the PHC Provider Directory.
Member Services bilingual staff are also available to assist LEP members with the selection process.
The Provider Directory reflects those provider offices that are wheelchair accessible.
13. Auto Assignment (Medi-Cal only) – The auto assignment process is configured to use the member’s
Page 3 of 10
Policy/Procedure Number: MP 302
Lead Department: Member Services
Policy/Procedure Title: Cultural and Linguistic Services
☒External Policy
☐Internal Policy
Original Date: 02/26/1999
Applies to:
☒ Medi-Cal
Next Review Date: 11/18/2016Last Review Date: 11/18/2015
☒ Healthy Kids
☐ Employees
language code and resident address.
14. PHC Member Service Staff (All Product Lines) – PHC’s goal is to staff the Member Services
Department with employees that are reflective of the cultural and linguistic diversity of PHC
membership.
15. Testing Linguistic Proficiency of PHC Staff (All Product Lines) – In accordance with Human
Resources policy #509, Bilingual Standards, the oral linguistic proficiency of all employees that
provide interpreting services to PHC members is tested. This is done to ensure that all the necessary
linguistic requirements are met. Only those employees that pass the test are allowed to provide oral
interpretation to PHC members. A copy of the test is maintained by PHC’s Human Resources
Department
16. Provider Network – (All Product Lines) PHC’s goal is to maintain a provider network with a
sufficient number of bilingual and multilingual providers and provider staff who speak threshold
languages. PHC requires that providers document the request or refusal of language/interpreter
services by LEP members in their medical record.
17. On an annual basis, PHC conducts provider self-reporting surveys to identify specific bilingual staff
at the provider sites. The survey questionnaire includes the following questions.
a. Is the language spoken the employee’s first language spoken at home?
b. Is the Employee a Certified Medical interpreter?
c. Has the employee had formal classroom education in the language?
d. Does your office assess employee interpretation ability?
18. The data collected from the survey is audited against the provider directory. The directories are
updated to reflect new information. As office staff changes are communicated to PHC, linguistic
capabilities of the new staff are added to the directory.
19. PHC continuously monitors issues related to provider interpreter capabilities through member
complaint and grievance logs. Corrective Action Plans are developed with provider sites if issues are
identified. PHC uses a variety of formats and tools to ensure providers are aware of interpreter
service options and educational opportunities for their staff. Examples: Quarterly provider newsletter
articles, PHC Provider Cultural and Linguistic Toolkit; links to Industry Collaboration Effort (ICE)
on the PHC website, reminders at provider site in-services, and provide a list of on-line courses and
community colleges that offer bilingual educational courses.
F. Provider Training & Education
1. PHC educates and trains providers and their staff on a) cultural competence; b) patient
communication; c) member satisfaction and/or complaints; d) federal and state regulations and
contract requirements relating to language access and anti-discriminatory practices, and e)
procedures for accessing PHC Interpreter Services, and the Language Line, the importance of using
qualified interpreters, discouraging the use of minors, friends or family members as interpreters,
documenting the member’s preferred language in their chart, and documenting the offer, acceptance
or refusal of interpreter services.
2. Seniors and Persons with Disabilities (SPD) competency and sensitivity training is provided to
providers, their staff and health plan staff utilizing the curriculum developed by Medi-Cal Managed
Care Division (MMCD).
3. Documentation of trainings is maintained by PHC and is available upon request in accordance to
DHCS MMCD APL 11-010.
G. Provider Language Capability
1. Providers are required to document their language capabilities on their initial application to become
contracted providers. PHC monitors linguistic capabilities through an annual survey of provider and
staff linguistic capabilities. Monitoring is also done through the site review process, during which
the facility site review nurse confirms staff linguistic capabilities and knowledge of the PHC
Page 4 of 10
Policy/Procedure Number: MP 302
Lead Department: Member Services
Policy/Procedure Title: Cultural and Linguistic Services
☒External Policy
☐Internal Policy
Original Date: 02/26/1999
Applies to:
☒ Medi-Cal
Next Review Date: 11/18/2016Last Review Date: 11/18/2015
☒ Healthy Kids
☐ Employees
procedure to access interpreter services and Language Line service.
H. Staff Training & Education
1. Plan staff who have routine contact with LEP members participate in internal department trainings
that include education on:
a. cultural awareness and sensitivity;
b. identifying and communicating with individuals who have limited English proficiency
c. interpretation and translation services and policies;
d. using the TTY/TDD and California Relay System; and
e. culturally and linguistically appropriate service referrals.
2. Referrals to Culturally and Linguistically Appropriate Services (All Product Lines) – Members are
referred to culturally and linguistically appropriate services, as needed.
3. Consumer Advisory Committee (CAC) (All Product Lines) – The PHC CAC provides information
and recommendations with respect to PHC’s C&L Services.
4. In accordance with MMCD Policy Letter 99-03, PHC will provide the following:
a. Interpreter services at key points of contact (medical and non-medical) for member whose
language proficiency is one of the threshold languages. Medical points of contact include faceto-face or telephone encounter with providers (physicians, physician extender, registered nurses,
pharmacists (at a minimum - telephone interpreter), or other personnel who provide medical or
health care advice to members.
I.
Criteria and Authorization Requirements for Interpreting Services (All Product Lines)
1. Telephonic Interpreter Services
a. Member or patient is being seen at a PHC contracted practice site.
b. Member or patient does not have other health coverage (OHC) that covers the
requested/required interpreting service.
c. Telephonic Interpreter Services do not require prior authorization through PHC’s Member
Services Department.
2. Sign Language Interpreters
a. Member is enrolled in PHC at the point the service is required.
b. Member does not have OHC that is primary to PHC that covers the requested/required
interpreting service.
c. Appointment is for a service that is covered by PHC.
d. Member is hearing and/or speech impaired.
e. Sign Language Interpretation services require prior authorization through PHC’s Member
Services Department.
3. Face-to-Face Interpreter Services
a. Member is enrolled in PHC at the point the service is required.
b. Member does not have OHC that is primary to PHC that covers the requested/required
interpreting service.
c. The appointment is for a service that is covered by PHC.
d. The appointment is for discussion of complex medical information such as diagnosis of complex
medical conditions and accompanying proposed treatment options; explanations of complicated
plans of care or discussion of complex procedures.
e. Face-to-face interpretation services require prior authorization through PHC’s Member Services
Department.
f. If face-to-face interpreter services are being requested at a hospital, PHC staff contacts the
Patient Services Department at the hospital for these services. If the hospital does not provide
these services, PHC arranges the service. Provider Relations Department is notified of hospitals
Page 5 of 10
Policy/Procedure Number: MP 302
Lead Department: Member Services
Policy/Procedure Title: Cultural and Linguistic Services
☒External Policy
☐Internal Policy
Original Date: 02/26/1999
Applies to:
☒ Medi-Cal
Next Review Date: 11/18/2016Last Review Date: 11/18/2015
☒ Healthy Kids
☐ Employees
refusal to provide service.
g. If face-to-face interpreter services are being requested for PHC Medi-Cal covered mental health
services, the caller is referred to Beacon at (855) 765-9703. Beacon is responsible to provide
face-to-face interpreting services. Members are advised to contact Beacon 3 business days in
advance of their appointment to arrange the service.
J.
Scheduling the Interpreting Services (All Product Lines)
1. Requests for face-to-face interpreting services are processed by the Call Center and Enrollment Unit
staff as outlined in document MS 22A-7 Face-to-Face Interpreting Services, available in the
Reference Manual.
2. PHC Member Service Department
a. After the interpreter services’ has been arranged, the designated Member Services staff
completes the Interpreter Services Log (attachment A). Upon receipt of the invoice, staff
compares the invoice to the log, ensuring that the billed services were approved by PHC and the
billed amount is correct. The MS Administrative Assistant then forwards the invoice to the PHC
Finance Department for payment.
K. Evaluation (All Product Lines)
1. The following methods are used to assess the linguistic capacity of the PHC primary care network
and the level of member satisfaction with linguistic services.
2. PHC membership is surveyed. The results are reviewed by C&L and Health Education committee to
determine if a corrective action plan is necessary.
3. PHC documents and monitors Member Complaints and Grievances related to Cultural and
Linguistic issues. Complaint and appeal reports that include cultural and linguistic issues are
presented to the Internal Quality Improvement (IQI) Committee on a quarterly basis for appropriate
action.
4. Annually, the Provider Relations & Member Services Departments reviews a report reflecting the
demographics of PHC members. This report includes a breakdown of PHC membership by race,
ethnicity written and spoken language. The Provider Relations Department uses this report to
analyze the linguistic capacity of the PHC primary care network. The Member Services Department
uses this information to determine threshold languages. If it is determined that the PHC primary care
network does not meet linguistic requirements in accordance with requirements, appropriate
Provider Relations staff develops a corrective action plan. The corrective action plan addresses the
need for additional linguistic services through the primary care network.
5. Review and approval of Corrective Action Plans
6. Appropriate PHC staff drafts a corrective action plan and presents it to the appropriate committee for
recommendations and approval. The corrective action plan is then returned to the appropriate
person(s) for implementation or incorporation of committee recommendations.
VII.
REFERENCES: N/A
VIII.
DISTRIBUTION:
A. Share Point
B. Provider Manuals (all lines of business)
IX.
POSITION RESPONSIBLE FOR IMPLEMENTING PROCEDURE:
Services
Senior Director of Member
Page 6 of 10
Policy/Procedure Number: MP 302
Lead Department: Member Services
Policy/Procedure Title: Cultural and Linguistic Services
☒External Policy
☐Internal Policy
Original Date: 02/26/1999
Applies to:
X.
☒ Medi-Cal
Next Review Date: 11/18/2016Last Review Date: 11/18/2015
☒ Healthy Kids
☐ Employees
REVISION DATES:
Medi-Cal
02/26/99; 04/09/02; 09/09/04; 05/12/05; 06/21/06; 03/12/08; 09/09/08; 09/19/09; 09/14/10; 12/21/10;
01/10/12; 05/15/13; 01/07/14; 05/13/14; 09/02/14
Healthy Kids
06/21/06; 03/12/08; 09/09/08; 09/19/09; 09/14/10; 12/21/10; 01/10/12; 05/15/13; 01/07/14; 05/13/14;
09/02/14
PREVIOUSLY APPLIED TO:
PartnershipAdvantage:
MP 302 – 06/2006 to 01/01/2015
Page 7 of 10
Attachment A
Interpreting Services Log
Program
Mbr
Amisys
#
Apt Date/
Time
Provider
Name
Provider
Address
Notes
Invoice #
Amount
Paid
Request Date
Date sent
to
Interpreter
(Rev. 3-2004)
Page 1 of 10
Attachment B
The organizations listed below are those used by PHC to assist Limited English Proficient members and members
with hearing and visual impairments.
Face-to-Face Interpreter Services
Language People, Inc. (provides face-to-face and sign language interpreters)
First Choice: For all counties except for Yolo County.
Second Choice: For Yolo County when Eastern European Interpreters is not available.
Second Choice: For ASL services in Shasta, Trinity, Siskiyou, Modoc and Lassen Counties when Tina L Cook Sign
Language Service is not available.
38750 Sky Canyon Drive, Suite C
Murrieta, CA 92563
(707) 538-8900
dispatch@bayareatranslations.com
Eastern European Interpreters (face-to-face language interpreters)
First Choice: for Yolo County
Second Choice: for all other counties when Language People, Inc., is not available.
P.O. Box 293591
Sacramento, CA 95829
(916) 600-1759 (ph)
(916) 682-8768 (ph)
(866) 779-0102 (fax)
POC: Mary Meekay
marmeekay@yahoo.com
Tina L Cook Sign Language Services
1st Choice for ASL services in PHC Counties Shasta, Trinity, Siskiyou, Modoc and Lassen Counties and
Non-PHC counties: Tehama and Butte.
ASL only
P.O. Box 219
Palo Cedro, CA 96073-0219
(530) 547-2744 (phone and fax)
Tquisha4@yahoo.com
Communique Sign Language Interpreting
Last choice for ASL services in PHC Counties, Solano, Napa, Yolo, Sonoma, Marin, Mendocino, Lake, Humboldt,
Shasta, Lassen, Trinity, Modoc, Del Norte, and Siskiyou Counties.
ASL only
330 College Ave.
Santa Rosa, CA 95401
(707) 546-6869, (707) 546-1770 Fax
www.CommuniqueInterpreting.com
scheduling@communiqueinterpreting.com (scheduling only)
Office hours Monday –Friday 8 am to 4 pm
Written Member Materials - All Counties
Written Language Interpreting
ViaLanguage
www.vialanguage.com
(800) 737-8481
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Braille and Audio Services
Lighthouse for the Blind & Visually Impaired
214 Van Ness Avenue
San Francisco, CA 94102
(415) 431-1481
ais@lighthouse-sf.org
CD’s, Diskettes and Large Print
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