BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                AB 1263
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        CONCURRENCE IN SENATE AMENDMENTS
        AB 1263 (John A. Pérez)
        As Amended July 10, 2013
        Majority vote
         
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        |ASSEMBLY:  |55-23|(May 29, 2013)  |SENATE: |25-9 |(September 11, |
        |           |     |                |        |     |2013)          |
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         Original Committee Reference:   HEALTH  

         SUMMARY  :  Establishes the Medi-Cal Patient Centered Communication  
        (CommuniCal) program at the Department of Health Care Services  
        (DHCS) to provide and reimburse for certified medical interpretation  
        services to limited English proficient (LEP) Medi-Cal enrollees.   
        Establishes a certification process and registry of CommuniCal  
        medical interpreters (CCMI) at DHCS and grants collective bargaining  
        rights with the state.

         The Senate amendments  

        1)Revise the certifying body to be DHCS instead of the California  
          Department of Human Resources (CalHR).

        2)Require DHCS to, by September 1, 2014, in consultation with the  
          Community Advisory Committee, approve an examination and  
          certification process to test and certify the competency of  
          medical interpreters and deletes the requirement that CalHR select  
          an examination within 120 days of implementation of this bill. 

        3)Require DHCS to establish a Community Advisory Committee as  
          specified.

        4)Require DHCS to develop, monitor, and evaluate interpreter  
          competency, qualifications, training, certification, and  
          continuing education requirements for medical interpreters.

        5)Add the following options as a condition of certification, in  
          addition to an examination administered by a nonprofit  
          organization:

           a)   Passes an examination developed by a state-established  
             language testing and certification program with a written and  
             oral component that meets specified standards;








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           b)   Achieves the designation of Certified Healthcare Interpreter  
             from the Certification Commission for Healthcare Interpreters  
             (CCHI);

           c)   Achieves the designation of Certified Medical Interpreter  
             from the National Board of Certification for Medical  
             Interpreters (NBCMI); or,

           d)   Holds a current interpreter's certification under existing  
             provisions.

        6)Add a process for authorizing CommuniCal services to be provided  
          by an interpreter of languages of lesser diffusion or languages  
          for which a CCCMI examination has not been created. 

        7)Revise requirement for a provisional authorization that allow  
          interpreters to be authorized prior to the development of the full  
          testing and certification program at DHCS and requires the person  
          meet the full standards by December 31, 2016. 

        8)Delete the requirement that the base reimbursement rate be set at  
          $60 per hour and instead provide that it be subject to collective  
          bargaining. 

        9)Make other technical and clarifying changes.

         FISCAL EFFECT  :  According to the Senate Appropriations Committee:

        1)One-time costs of $1.4 million to develop program guidelines, seek  
          necessary federal approvals, and develop billing systems (50%  
          General Fund (GF), 50% federal funds). 

        2)One-time costs of about $50,000 to develop regulations relating to  
          collective bargaining of translators by PERB (GF). 

        3)One-time costs of about $90,000 and ongoing costs of about $50,000  
          to oversee an election by translators to choose a collective  
          bargaining agent by PERB (GF). 

        4)Periodic costs up to $1 million for negotiating a memorandum of  
          understanding with the established bargaining unit and overseeing  
          the implementation by the Department of Human Resources (GF). 

        5)Ongoing costs of about $30 million per year to provide translation  








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          services in fee-for-service Medi-Cal (GF and federal funds). 

        6)Unknown costs in Medi-Cal managed care (GF and federal funds).   
          Under current law, health plans are required to provide  
          interpretation services, including managed care plans that  
          contract with DHCS.  It is unclear whether the bill's requirement  
          to provide "certified medical interpretation services" at  
          reimbursement rates subject to collective bargaining would  
          increase costs for translation services, above the costs already  
          being incurred. 

        7)The federal financial participation rate for the costs above may  
          vary. For interpretive services provided to children and their  
          family members, the state can claim a 75% federal financial  
          participation rate. However, those costs are only eligible for a  
          75% federal cost share if they are billed as administrative costs  
          (as opposed to benefits).  For childless adults, the rate is  
          generally 50%. 

         COMMENTS  :  According to the author, this bill is to establish a  
        program to provide and reimburse for medical interpretation services  
        to LEP Medi-Cal enrollees and to allow for collective bargaining for  
        certified medical interpreters.  The author cites data that show  
        more than 40% of Californians speak a language other than English at  
        home.  In addition, almost seven million Californians are estimated  
        to speak English "less than very well."  Other research finds that  
        language barriers can contribute to inadequate patient evaluation  
        and diagnosis, lack of appropriate and/or timely treatment, or other  
        medical errors that can jeopardize patient safety and lead to  
        unnecessary procedures and costs.  The author argues that today,  
        language assistance in medical settings is provided by trained or  
        untrained staff or in an informal manner by family members or  
        friends.  In conclusion, the author states that California has an  
        opportunity to develop a more comprehensive language assistance  
        program by seeking additional federal funding for medical  
        interpreter services in the Medi-Cal program.
        The Children's Health Insurance Program Reauthorization Act (CHIPRA)  
        of 2009 contains provisions that affect both the federal Children's  
        Health Insurance Program (CHIP) and Medicaid.  In July 2010, the  
        Centers for Medicare and Medicaid Services provided guidance on the  
        implementation of the provisions of CHIPRA relating to increased  
        administrative funding for translation or interpretation services  
        provided under CHIP and Medicaid.  For Medicaid, increased federal  
        funding for translation and interpretation services available under  
        CHIPRA is limited to children and family members of those children.   








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        For CHIP, increased federal funding for translation and  
        interpretation services is not just limited to children, and  
        includes pregnant women receiving CHIP coverage.  Prior to CHIPRA,  
        states could claim federal matching funds for translation or  
        interpretation costs as either an administration expense or as a  
        medical assistance-related expense, and were reimbursed at the  
        standard Federal Medical Assistance Percentage (regular FMAP rate  
        which in California is typically 50% for Medi-Cal and 65% for the  
        Healthy Families Program (HFP)).  Although children in the HFP are  
        currently transitioning to Medi-Cal, it is still considered a CHIP  
        program for FMAP purposes.  CHIPRA provides increased federal  
        matching funding for translation or interpretation services provided  
        to eligible individuals for whom English is not their primary  
        language.  The increased FMAP for translation or interpretation  
        services differs for Medicaid and CHIP.  For Medicaid, the increased  
        match is 75% of allowable expenditures.  For CHIP, the increased  
        match is 75%, or the State's enhanced FMAP plus 5%, whichever is  
        higher (in California, it would be 75%).  However, the increased  
        FMAP is only available for eligible expenditures claimed for  
        administration of the Medicaid or CHIP plan, and not expenditures  
        claimed for benefits (which are matched at the State's usual FMAP  
        rate of 50% for Medi-Cal and 65% for CHIP).  In addition, the  
        expenditures that qualify for the increased match under CHIP are  
        subject to the 10% cap on administrative expenditures.

        Supporters such as Interpreting for California, The Low-Income  
        Self-Help Center and Catholic Charities of Santa Clara County, write  
        that this bill address the need for interpreters in Medi-Cal as the  
        state will experience greater demand when 35% of the newly eligible  
        enrollees speak English less than well.  These supporters state that  
        this bill will make it possible for the 2.5 million Medi-Cal  
        enrollees who are LEP to communicate with healthcare providers,  
        reducing medical errors and improving the standard of care by  
        providing access to trained interpreters.  Other supporters such as  
        The American Federation of State, County and Municipal Employees,  
        AFL-CIO and Somos Mayfair writes in support that, with the expansion  
        of Medi-Cal and the implementation of the California Health Benefit  
        Exchange under federal health care reform, the State has a clear  
        opportunity to create an interpreters' program that will allow  
        patients and providers to clearly communicate with each other.   
        According to these supporters, in 2003 California passed the  
        strongest law in the country requiring all private health plans to  
        provide language assistance services to LEP individuals beginning in  
        2009.  However, the supporters assert, patient interpretation needs  
        remain unmet despite these laws and explicit policy directives to  








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        Medi-Cal managed care plans to provide interpreter services.   
        According to the Transnational Institute for Grassroots Research and  
        Action (TIGRA), LEP Californians frequently reported problems  
        related to their experience of care.  TIGRA asserts that LEP  
        enrollees of the state's seven largest health plans were more likely  
        than English proficient enrollees to report problems understanding  
        their physician (1.2% versus 2.6%) and believe they would have  
        received better care if they were of a different race/ethnicity (14%  
        versus 3.2%).  


         Analysis Prepared by  :    Marjorie Swartz / HEALTH / (916) 319-2097 


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