BILL ANALYSIS                                                                                                                                                                                                    Ó



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            ASSEMBLY THIRD READING
          AB 2392 (John A. Pérez)
          As Amended May 25, 2012
          Majority vote 

           HEALTH              14-5        APPROPRIATIONS      12-5        
           
           ----------------------------------------------------------------- 
          |Ayes:|Monning, Ammiano, Atkins, |Ayes:|Fuentes, Blumenfield,     |
          |     |Bonilla, Eng, Gordon,     |     |Bradford, Charles         |
          |     |Hayashi,                  |     |Calderon, Campos, Davis,  |
          |     |Roger Hernández, Bonnie   |     |Gatto, Ammiano, Hill,     |
          |     |Lowenthal, Mitchell,      |     |Lara, Mitchell, Solorio   |
          |     |Nestande, Pan,            |     |                          |
          |     |V. Manuel Pérez, Williams |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Logue, Garrick, Mansoor,  |Nays:|Harkey, Donnelly,         |
          |     |Silva, Smyth              |     |Nielsen, Norby, Wagner    |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Requires the Department of Health Care Services (DHCS) 
          to seek federal funding to establish a program to provide and 
          reimburse certified medical interpretation services to Medi-Cal 
          beneficiaries with limited English proficiency (LEP).  
          Specifically,  this bill  :

          1)Requires the program to offer medical interpreter services to 
            Medi-Cal providers serving Medi-Cal beneficiaries in 
            fee-for-service (FFS) or Medi-Cal managed care (MCMC) and 
            allows Medi-Cal approved providers and MCMC contracting and 
            subcontracting plans to utilize the program to provide 
            interpreter services to Medi-Cal beneficiaries.

          2)Requires all contracts between MCMC plans and subcontractors, 
            including those with providers and other plans, to include 
            provisions describing access to medical interpreter services 
            under this program. 

          3)Requires DHCS to pursue all available sources of funding to 
            establish and administer this program, to develop a mechanism 
            to leverage existing sources of funding associated with 
            medical interpretation services in order to offset state 
            General Fund (GF) costs and to seek any federal approvals 








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            necessary. 

          4)Specifies legislative intent including:  to create a program 
            to provide reliable access to language interpretation to 
            Medi-Cal beneficiaries who are LEP; to enable trained and 
            qualified interpreters to meet the demand for language 
            services; and, to facilitate accurate and timely communication 
            between LEP patients and their health care providers. 

           FISCAL EFFECT  :  According to the Assembly Appropriations 
          Committee:

          1)Costs for a number of activities as noted below.  Costs would 
            generally be at a 50% GF, 50% federal funds matching rate 
            except for costs associated with services used by children, 
            subject to federal approval.  Pursuant to the Children's 
            Health Insurance Program Reauthorization Act of 2010 and 
            subsequent federal guidance, language services for children 
            can be claimed at a 25% GF, 75% federal funds matching rate.  
            Children comprise approximately half of the Medi-Cal 
            population.

          2)This bill requires the department to develop a mechanism to 
            leverage existing funding associated with medical 
            interpretation services, in order to fully offset increased 
            state GF costs.  Thus, the only net state costs are the 
            following:

             a)   One-time administrative costs in the range of $1 million 
               (50% GF, 50% federal funds) to DHCS to seek federal 
               approvals, create system protocols, develop an information 
               technology or 'IT' infrastructure, design communications 
               and guidance, promulgate regulations, consult with 
               stakeholders, and other initial program development 
               activities.

             b)   If DHCS establishes an accreditation system for 
               qualifying language providers as stated in the intent 
               language of this bill, one-time costs of $100,000 (50% GF, 
               50% federal funds) to develop standards and promulgate 
               regulations, as well as $50,000 or more ongoing to 
               credential these providers.

          3)The extent to which a centralized medical interpretation 








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            system would increase the number of medical interpretation 
            visits, given that the program would have to rely on 
            leveraging existing funding for these purposes, is unknown.  
            The availability of enhanced 75% federal match for services 
            provided to children through a centrally administered system, 
            and the potential for increased cost efficiency of such a 
            system, suggests it may be possible to increase the number and 
            quality of visits provided, with negligible additional state 
            costs.

          4)Potential impact on medical services used is also difficult to 
            estimate, but improved access to high-quality interpretive 
            services is likely to improve access to care and, on balance, 
            increase overall medical costs to the Medi-Cal program for LEP 
            beneficiaries.  

           COMMENTS  :  According to the author, this bill is to require DHCS 
          to explore options for obtaining federal matching funds in the 
          Medi-Cal program for the reimbursement of medical interpretation 
          services to beneficiaries who are LEP.  The author points out 
          that more than 40% of Californians speak a language other than 
          English at home.  Furthermore, almost seven million Californians 
          are estimated to speak English "less than very well."  The 
          author states that research has found 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 further points out that 
          currently language assistance in medical settings is provided by 
          trained or untrained staff or in an informal manner by family 
          members or friends.  The author argues that with this bill, 
          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.

          In 2002, the federal Centers for Medicare and Medicaid Services 
          released a letter to all state Medicaid directors reminding 
          states that federal matching funds are available for states' 
          expenditures related to the provision of oral and written 
          translation administrative activities and services provided for 
          Medicaid recipients.  According to the letter, federal financial 
          participation is available for such activities or services 
          whether provided by staff interpreters, contract interpreters, 








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          or through a telephone service.  Nonetheless, in California 
          there is no mechanism to reimburse for language services in the 
          FFS system as there is no billing code.  

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

                                                                FN: 0003953