Risk Management of the LEP Patient and Effective Language
Access Plans for 2012: Problems and Solutions to Reach
Compliance With The Joint Commission Standards
Armando Ezquerra Hasbun, Director of Programs, LSA
Shiva Bidar-Sielaff, CCHI Commissioner

LSA Company Overview
About LSA
Founded in 1991 by Laura K.T. Schriver
Horsham, PA headquarters
A network of more than 5,000 Independently Contracted global Linguists
Recently named to Common Sense Advisory’s list of “Top Global
Language Services Providers” for the second consecutive year
Over 200 language offerings
100% privately owned
Certified Diversity Enterprise (WMBE)

LSA Company Overview
LSA is proud to offer a full range of language translation services and language interpreter services:

Webinar Objectives
Discuss the current regulatory requirements governing Language
Access Plans for LEP populations in healthcare settings
Learn more about the problems healthcare providers and administrators typically encounter when implementing an effective
Language Access Plan
Review the recommended options, strategies and solutions to meet
Joint Commission Standards, with the ultimate goal of achieving optimal outcomes for all
Understand the importance of using certified and credentialed medical interpreters when caring for an LEP patient, and what certification and credentialing means to The Joint Commission
You are invited to share your experiences, in terms of challenges and successes, at the end of the Webinar during the Q&A session.

The Joint Commission (TJC)
The Joint Commission is an independent, not-for-profit organization that accredits and certifies more than 19,000 health care organizations and programs in the United States. A majority of state governments recognize Joint Commission accreditation as a condition of licensure and the receipt of Medicaid reimbursement.
Surveys (inspections) typically follow a triennial cycle, with findings made available to the public in an accreditation quality report.
The declared mission of the organization is:
"To continuously improve health care for the public, in collaboration with other stakeholders, by evaluating health care organizations and inspiring them to excel in providing safe and effective care of the highest quality and value.”

Key Guidelines Regarding Equal
Language Access Standards
PC.02.01.21: The hospital effectively communicates with patients when providing care, treatment and services.
EP 1: The hospital identifies the patient’s oral and written communication needs, including the patient’s preferred language for discussing health care.
EP 2: The hospital communicates with the patient during the provision of care, treatment and services in a manner that meets the patient’s oral and written communication needs.
Title VI of the Civil Rights Act of 1964 prohibits discrimination based on “national origin,” which includes language.
The Americans with Disabilities Act of 1990
Section 504 of the Rehabilitation Act of 1973

How Are Health Care Providers
Responding?
Some of the larger providers are at the vanguard, and are setting an example on how to successfully achieve equal language access; on the other hand, the majority of smaller providers are finding themselves in one of the positions listed below:
Rushing to try and meet compliance deadlines
Trying to make sense of guidelines that are not explicit
Struggling for funding that has not been budgeted for
At a loss as to how well their language needs are being met
Having to design, document and perfect their response

The Language Access Plan
The first step to achieving equal language access is to create, develop, apply and continuously supervise your institution’s
Language Access Plan
A Language Access Plan is the roadmap that is created to reflect:
The linguistic needs of the community your institution serves
Your arrangements for meeting those needs
Your system for the provision of interpretation services:
Staff face-to-face interpreters
Per-diem face-to-face interpreters contracted directly
Per-diem face-to-face interpreters from agencies
Remote interpreters from provider pools
Remote telephonic interpreters from language services providers
Remote VRI interpreters from language services providers

Language Access Plan on Interpretation
HR.01.02.01:
It is not appropriate to rely on untrained individuals as the primary source for bridging communication barriers during medical encounters with individuals who are deaf or speak a language other than English. Requirement HR. 01.02.01, EP1 requires hospitals to define staff qualifications specific to job responsibilities.
Note 4 in EP 1 requires hospitals to specifically ensure that individuals who provide interpreting and translation services in the hospital have defined qualifications and competencies .

Language Access Plan on the Use of
Untrained Interpreters
Untrained individuals – including family members, friends, other patients and / or untrained bilingual staff – should not be used to provide language access services during medical encounters.
Standard HR.01.02.01: The hospital defines staff qualifications
“Qualifications for language interpreters and translators may be met through language proficiency assessment, education, training and experience.”

Problems and Possibilities
Lack of Institutional Support
My institution doesn’t budget for contracting language services
My institution doesn’t have policies in place regarding the proper use of interpreters
My institution relies on bilinguals and doesn’t see the need to do it any other way
Lack of Trained Interpreters
Our in-house team has never been trained
Our bilingual personnel has not been tested
We cannot possibly provide interpreters:
In all the languages that show up
In all the medical subspecialties needed
At all hours of the day and night
We cannot be sure how our team performs

Problems and Possibilities
Multiple Solutions but No Accountability
How can we test for language skills?
How can we determine interpreting ability?
We can’t tell how well an interpreter performs
Conflicts of interest and ethical dilemmas
Correct language but much misunderstanding
Can we rely on “Certified” interpreters?
Trained, Qualified, Certified?
The 40-hour specialized training course
The ‘Training the Trainer’ course
The National Certification options available
Health Care Interpreter Qualification
Continued Education and Remote Learning
English and Languages of Limited Diffusion

Problems and Possibilities
Opposition From All Sides: A Shift in Perception and Attitude Is Needed
Providers see the process as cumbersome; causes delays
Bilingual providers use their own language skills
Patients rely on their own family and friends
Dual-role employees have extra duties and no pay differential
Remote interpreting has major limitations
Technophobes tend to under use available services

Problems and Possibilities
Understanding Professional Interpreters
Knowledge, skills and ability
Training, testing and acquisition of credentials
Applied ethics
Protocol and common standards of practice
Protocol and best practices
Linguistic limitations – consulting the dictionary
Roles and what an Interpreter cannot do
A typical day in the life of a healthcare Interpreter

Problems and Possibilities
Sources of Recurrent Problems
Sudden re-scheduling and cancellations
Reported times and billing reconciliation
How to manage the INFORMED CONSENT FORM
Errors, inaccuracies and incomplete interpretation
The interpreter takes over control of the session
Side conversations in the foreign language
Cannot hear well; disconnections
The interpreter is argumentative or impolite

How LSA Can Help
LSA supports you in your mission by:
Helping providers assess their bilingual dual-role staff
Providing training courses to help make interpreters qualified to sit in for the certification examination
Offering continuing education educational sessions on specialized topics for your interpreter corps
Training your providers on how to work with interpreters
Delivering a full range of services to help providers achieve their goals of better outcomes, while meeting all specifications of a
Language Access Plan; LSA’s full suite of services includes:
Translation & Localization
Video Remote Interpreting
Interpreting by Telephone
Face-to-Face Interpreting
American Sign Language
Intercultural Consulting

Healthcare Interpreter Certification
Shiva Bidar-Sielaff
CCHI Commissioner

Why is Credentialing Important?
No federal regulations for the healthcare interpreting profession exist
Very few state regulations exist
Major organizations understand importance of competent interpreters:
Office for Civil Rights
Office of Minority Health
The Joint Commission

New Joint Commission Standards
The patient-centered communication standards, approved in
December 2009 and released in January 2010, became effective on July 1 st , 2012:
HR.01.02.01., EP 1: Individuals providing interpreting or translation services have defined qualifications or competencies
Qualifications for language interpreters may be met through
Assessment (AHI and CHI tests)
Education (U.S. High School or equivalent)
Training (Minimum of 40 hours & Continuing Education)
Experience

Certification Commission for
Healthcare Interpreters
CCHI (Certification Commission for Healthcare Interpreters) –
“One Voice”
One set of industry-formed standards
Assurance of competency
Professional certification program
Involving
Interpreters
Employees and independent contractors
Users of interpreter services
Bringing together the necessary stakeholders through a non-profit organization

Why CCHI Credentials?
The AHI TM and CHI TM examinations follow the blueprint created by the Job Task Analysis (JTA)
Exams were developed according to NCCA Standards, under direct oversight of CCHI
CCHI exams have been psychometrically validated
Over 1,250 applicants since testing began
509 interpreters nationwide have already earned their CCHI credentials – 165 AHI TM and 344 CHI TM

Test Development Supporters
Note: The participation by supporters does not constitute ultimate endorsement of CCHI’s certification program.

CCHI Current Credentials
Associate Healthcare Interpreter TM Credential (AHI TM )
Available to all interpreters except Spanish-, Arabic- and Mandarinspeaking interpreters
Certified Healthcare Interpreter TM Certification (CHI TM )
Currently available to Spanish-, Arabic- and Mandarin-speaking interpreters

What Is the Associate Healthcare
Interpreter TM (AHI TM ) Credential?
Available to interpreters in ALL languages
Entry point into professional certification
Two-hour, computer-based, 100 question, multiple choice exam in English
Tests the basics of health care interpreting
Preliminary results are immediate at test center
Credential awarded upon successful completion of the written examination (except for Interpreters who are eligible for CHI TM )

The AHI TM Examination
Managing an Interpreting Encounter
Healthcare Terminology
Interacting With Other Healthcare Professionals
Preparing for an Interpreting Encounter
Demonstrating Cultural Responsiveness
30% - 35%
22% - 25%
20% - 24%
16% - 20%
3% - 6%

What is the Certified Healthcare
Interpreter TM (CHI TM ) Certification?
Currently available in Spanish, Arabic and Mandarin; other languages will continue to be developed
Tests the basics of health care interpreting plus interpreting skills and abilities
AHI TM examination + computer-based oral performance examination (takes one hour to complete) = Certification

The CHI TM Examination
Knowledge required of health care interpreters (same as AHI TM credential)
Interpreting in a health care environment: accurately and completely within a cultural and environmental context:
Interpret consecutively 75 – 80%
Interpret simultaneously 10 – 15%
Sight translate and translate healthcare documents 10 – 15%

Application:
AHI TM :
CHI TM :
$30 ( non-refundable )
$175
$250
$455 total for Spanish-, Mandarin- and Arabic-speaking interpreters
$205 for all other interpreters
All fees are non-refundable
This is for one examination administration
Fees

Credential / Certification Maintenance
CHI TM certification and AHI TM credential are valid for four years
Maintenance Requirements
32 hours total Continuing Education = 16 hours (classroom or contact) in years 1 & 2, 16 hours in years 3 & 4
40 hours of work experience = 20 hours in years 1 & 2, 20 hours in years 3 & 4

www.healthcareinterpretercertification.org
info@healthcareinterpretercertification.org
CCHI

Armando Ezquerra Hasbun
Director of Programs, LSA ahasbun@lsaweb.com
www.lsaweb.com
Shiva Bidar-Sielaff
CCHI Commissioner bidarsielaff@healthcareinterpretercertification.org
www.healthcareinterpretercertification.org

Q&A Session
Face-to-Face Interpreting Video Remote Interpreting (VRI)
Translation and Localization American Sign Language (ASL) Intercultural Consulting