The following, prepared by the Language Task Force, represents what we believe area hospitals should do in order to comply with Title VI of the Civil Rights Act of 1964, 2000d et seq. and to serve the health needs of Limited English Proficiency (LEP) patients. [For more discussion of Title VI, see Department of Health and Human Services, Guidance Memorandum, Title VI -- Prohibition Against National Origin Discrimination -- Persons with Limited English Proficiency, available from Office for Civil Rights, Region V, 105 W. Adams, 16th floor, Chicago, IL 60603.]

Each Hospital Should:

1. Establish a coordinator of interpreter services, a person who screens, hires, and schedules interpreters for all inpatient and outpatient needs and ensures that hospital employees know and comply with all established policies and procedures for interpreter services.

2. Establish a pool of qualified medical interpreters* to serve all LEP patients.

• Interpreters are professionals who must be paid for their work.
• Hospitals should hire interpreters on an on-call basis for main languages, available on-call 24 hours a day; if need warrants, hire full- or part-time, on-site interpreters.

*Qualified medical interpreter: one who is fluent in both the LEP patient's primary language and English, including medical terminology in both languages; one who understands and who agrees to follow confidentiality rules and a Medical Interpreter Code of Ethics adopted by hospitals with input from a representative task force (outlined below). The Language Task Force is available to assist in training and identifying qualified medical interpreters (see "Training", below).

3. Establish a Uniform Training Requirement for All Interpreters. In order to ensure that all medical interpreters are qualified, a uniform training requirement must be established. The Language Task Force will offer its resources to assist in developing a training program for medical interpreters. This could be shared by all of the hospitals.

4. Establish Medical Interpreter Code of Ethics or Ethical Standards. Each hospital, with input from its task force (see number 7, below) and the Language Task Force, must develop or adopt a Medical Interpreter Code of Ethics, or ethical standards. Each medical interpreter must agree to abide by the ethical standards before being employed as a medical interpreter.

5. Establish a written Interpretive Services Policy and Procedures. The policy should include:

• Creating a procedure for identifying the language needs of patients/clients. [Guidance Memorandum, supra, page 5.] This occurs when patients schedule appointments or appear for services at the hospital. All staff who register patients or schedule appointments must be aware of the procedures.
• Recording information on language in the hospital's central database, including whether an interpreter is required and for what language.
• Informing all hospital staff about procedures for requesting interpreters for inpatients.
• Documenting the translator's identity in the medical record for each major medical encounter, such as informed consent or discharge planning.

6. Collect data on numbers of LEP inpatient and outpatient encounters, to document the need for translation services, review data and determine need for better data collection. Language need for each patient should be entered into central data system. Usage of interpreters, including day and time, language, identify of interpreter and cost, should be documented for each patient.

7. Create a task force within the hospital system to establish the Interpreter Services program, including representatives from: senior administration; clinicians with large LEP populations; social services; information system department; legal or risk management; and LTF members from communities such as Hispanic, Asian, Russian, Somali.

8. Translate written forms, policies, signs and handouts in major languages: Commonly used forms, policies, and signs, such as the intake form, free care policy, and financial aid form, should be translated into the most commonly used languages at the hospital. Market bi-lingual services. Provide handouts and signs informing patients of the right to request an interpreter.

9. Increase hiring of bilingual employees: Hiring policies should consider language skills for all positions in the hospital. Recruiting bilingual providers and staff, including residents and other trainees, will increase the hospital's capability to meet the needs of LEP patients. However, interpreting should be included in the job description of individuals whom the hospital intends to use for interpreting on a regular basis. These individuals should meet the same standards described above for interpreters.

10. Cultural competency training: Hospitals must provide training to hospital employees at all levels, both on cultural competency on specific cultures and cross-cultural training. Many differences exist among cultures in ways of communicating about health problems, treatment of those that are ill, and perception of certain illnesses. Cultural competency training will help increase understanding of these important issues and improve the provision of services to people of different cultures.

11. Assess need on a continuing basis: The hospital must identify the primary language needs of patients using the hospital, including an approximate number of patients who speak each language and number of visits by LEP patients. By developing systems to track these numbers, the hospital can then determine interpreter needs.

12. Budget sufficient funding to pay for needed interpreter services.