BILL ANALYSIS Ó
SENATE COMMITTEE ON HEALTH
Senator Ed Hernandez, O.D., Chair
BILL NO: AB 2392
AUTHOR: John A. Pérez
AMENDED: August 21, 2012
HEARING DATE: August 23, 2012
CONSULTANT: Bain
PURSUANT TO SENATE RULE 29.10
SUBJECT : Medi-Cal: CommuniCal.
SUMMARY : Requires the Department of Health Care Services (DHCS)
to establish the CommuniCal program to provide and reimburse for
certified medical interpretation services provided to Medi-Cal
beneficiaries who are limited English proficient (LEP).
Establishes the State Personnel Board (SPB) as the certifying
body for the CommuniCal certified medical interpreter (CCMI)
program established by this bill. Requires CommuniCal to be
administered by a patient-centered communication broker that is
a third-party administrator.
Existing law:
1.Establishes the Medi-Cal program, which is administered by
DHCS, under which qualified low-income individuals receive
health care services.
2.Provides, under federal law, increased federal matching
funding for translation and interpretation services provided
in connection with the enrollment, retention, and use of
services under Medicaid (Medicaid is known as Medi-Cal in
California) and the Children's Health Insurance Program (CHIP
is known as the Healthy Families Program in California).
3.Prohibits, under Title VI of the Civil Rights Act of 1964, a
person in the United States, on the grounds of race, color, or
national origin, from being excluded from participation in,
denied the benefits of, or subjected to discrimination under
any program or activity receiving federal financial
assistance.
This bill:
1.Requires the SPB to serve as the CCMI certifying body.
Requires the certifying body to select an examination through
which competency will be tested and provide for the
Continued---
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certification of Spanish-language medical interpretation
within 120 days of the implementation.
2.Requires the examination to be known as the CCMI Exam, and
requires the exam to have both an oral and a written
component.
3.Requires the oral component to be conducted in person in each
of the major metropolitan areas in California.
4.Requires the certifying body to select a nonprofit
organization to administer the exam, and requires the
nonprofit organization to have a statewide presence.
5.Requires a list of all interpreters who pass the exam to be
maintained by the certifying body. Requires this list to be
known as the CCMI Registry.
6.Defines a CCMI as someone who has passed the exam, is listed
on the registry, and has been issued a certificate by the
certifying body attesting that the person is a CCMI.
7.Requires, commencing July 1, 20l3, in order to be eligible to
provide services under CommuniCal, Spanish-language
interpreters to be required to pass the exam and be listed on
the registry.
8.Requires the certifying body, for those languages of lesser
diffusion or languages for which a recognized medical
interpreter exam has not been created, to determine, with
certified medical interpreters, appropriate testing, training,
and experience standards for interpreters to be placed on the
registry and listed as a CCMI. Requires the certifying body to
meet this requirement by July 1, 2013.
9.Requires all interpreters who have been previously otherwise
certified as medical interpreters by the certifying body to be
immediately listed on the registry within 30 days of the
operative date.
10.Requires the certifying body to establish and charge fees,
which do not exceed the reasonable costs, for applicants to
take the exam. Requires the certifying body to establish and
charge a single fee that does not exceed the reasonable costs
for certification and listing on the registry. Requires that
the purpose of these fees is to cover the annual projected
costs of carrying out this bill. Permits the fees to be
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adjusted each fiscal year by a percent that is equal to or
less than the percent change in the California Necessities
Index prepared by the Commission on State Finance.
11.Requires each CCMI to pay a registry and certification fee,
not to exceed the reasonable costs, for the renewal of the
certification and continued listing on the registry that is
due on July 1 of each year. Waives the certification and
listing fee for the 2013-14 fiscal year only.
12.Requires the certifying body to establish, maintain,
administer, and annually publish an updated registry of CCMIs.
13.Permits the certifying body to remove the name of a person
from the registry if any of the following conditions occurs:
a. The person is deceased;
b. The person notifies the SPB that the person is
unavailable for work; or
c. The person does not submit a required registry and
certification fee or renewal fee.
14.Requires the certifying body to adopt quality standards and
medical interpretation certification requirements through
regulation, to determine the testing requirements for
certification in each language, and to create a list of those
languages where standards permit registration of the
interpreter.
15.Requires DHCS to establish the CommuniCal program to provide
and reimburse for certified medical interpretation services to
Medi-Cal beneficiaries who are LEP.
16.Requires, commencing July 1, 2013, CommuniCal to offer
medical interpreter services to Medi-Cal providers serving
Medi-Cal beneficiaries on either a fee-for-service or managed
care basis.
17.Permits a health care provider or entity entering into a
Medi-Cal provider agreement or a Medi-Cal managed care
contract with the state, including Medi-Cal Managed Care
Organizations (MMCOs), their subcontracting plans, and
fee-for-service providers, to utilize CommuniCal to provide
medical interpreter services to Medi-Cal beneficiaries.
18.Requires all contracts between MMCOs and their
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subcontractors, including health providers and other health
plans, to include provisions describing access to CommuniCal
medical interpreter services.
19.Requires DHCS to pursue all available sources of federal
funding to establish and operate CommuniCal and to seek any
federal approvals necessary to implement this bill.
20.Requires CommuniCal to include the provision of in-person,
telephonic, and video medical interpretation services.
Requires, to meet language access requirements and to ensure
patient safety, in-person interpreter services to be the
preferred mode of medical interpretation in the following
instances, whenever possible:
a. Family meetings regarding medical care;
b. Medical encounters involving difficult or agitated
patients;
c. Medical encounters to make treatment decisions;
d. Obtaining informed consent involving review of
documents;
e. Any medical encounter that, in the physician's judgment,
requires in-person interpretation for the health, safety,
or well-being of the patient;
f. Psychiatric encounters; and
g. End-of-life discussions.
21.Requires CommuniCal to be administered by a patient-centered
communication broker. Defines a "patient-centered
communication broker" or "broker" as the third-party
administrator for the CommuniCal program.
22.Requires DHCS to create and administer a competitive Request
for Proposals (RFP), and to execute the resulting contract.
23.Requires the broker to be responsible for all of the
following duties:
a. Registering CCMIs with Medi-Cal;
b. Verifying CCMI certification with the SPB;
c. Verifying Medi-Cal eligibility for interpreter services
utilizing the state's Medi-Cal Eligibility Data System;
d. Submitting billing summaries to Medi-Cal, aggregating
the cost for services provided;
e. Ensuring compliance with all Medi-Cal and applicable
CommuniCal reporting requirements;
f. Making payments to CCMls, including any dues and service
fee deductions;
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g. Scheduling CCMI appointments with Medi-Cal providers;
h. Monitoring the quality of CommuniCal interpreter
services and complying with state oversight requirements of
the program; and
i. Creating CommuniCal promotional materials for
distribution to Medi-Cal providers, MMCOs, and
beneficiaries.
24.Requires DHCS to make all applicable Medi-Cal reporting
requirements known to the broker and to be responsible for the
broker's compliance with these requirements.
25.Allows only interpreters certified under this bill to
participate in CommuniCal.
26.Requires CCMIs to be responsible for all of the following:
a. Performing interpreter services independent of other
policies, rules, or procedures of conduct, except as
provided by this bill or by applicable law;
b. Performing interpreter services independent of
direction, except as otherwise provided by this bill and
applicable law;
c. Preparing and submitting documentation to the broker in
support of time worked or other services rendered; and
d. Directing and controlling the manner and means of
interpretation services, except as otherwise provided in
this bill.
27.Permits CCMIs, unless otherwise prohibited by this bill or
applicable law, to do any of the following:
a. Advertise, promote, or otherwise communicate
availability for services to clients and the general
public; and
b. Provide office space, equipment, support services,
forms, supplies, and business cards, except as otherwise
provided in this bill.
28.Requires DHCS to issue guidance on the administration of the
CommuniCal program to ensure compliance with this bill and all
applicable state and federal laws by all contractors and
subcontractors of the program.
29.Establishes the CommuniCal Program Fund in the State
Treasury. Requires any interest and dividends earned on
deposits in the fund to be retained in the fund. Requires
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moneys in the fund to consist of any funds dedicated to the
CommuniCal program. Requires moneys in the fund, upon
appropriation by the Legislature to DHCS, to be used solely to
fund the CommuniCal program.
30.Makes legislative findings and declarations regarding the
number of languages spoken in California, that approximately
one in five Californians is LEP, current language access
requirements and the right to interpretation services, the
demand for interpretation services, that language assistance
services are currently provided in an uncoordinated and ad hoc
manner, that California has the opportunity to meet this
demand by accessing millions of dollars in federal matching
funds to provide medical interpretation services to LEP
Medi-Cal beneficiaries, and the benefit of a coordinated
program to offer medical interpreter services.
31.States legislative intent to:
a. Create the CommuniCal program, which is required to
provide reliable access to language interpretation for
Medi-Cal beneficiaries who are LEP.
b. Establish a mechanism for accessing federal Medicaid
matching funds to provide a majority of the funding for the
CommuniCal program.
c. Enable trained and qualified interpreters to meet the
demand for language services for a significant portion of
the estimated three million Medi-Cal beneficiaries with
LEP.
d. Facilitate accurate and timely communication between LEP
patients and their health care providers, which will
improve quality of care, reduce medical errors, increase
patient understanding and compliance with health diagnoses
and care plans, and reduce the cost of health care by
eliminating waste, such as unnecessary tests and other
care.
FISCAL EFFECT : According to the Senate Appropriations Committee
analysis of the previous version of this bill:
1.One-time costs likely in the hundreds of thousands to develop
program guidelines, seek necessary federal approvals, and
develop billing systems.
2.Ongoing costs of about $30 million per year to provide
translation services in fee-for-service Medi-Cal.
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3.Unknown costs in Medi-Cal managed care. Under current law,
health plans are required to provide interpretation services,
including managed care plans that contract with the Department
of Health Care Services. It is unclear whether the bill's
requirement to provide "certified medical interpretation
services" would increase costs for translation services, above
the costs already being incurred.
4.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 percent federal
financial participation rate. However, those costs are only
eligible for a 75 percent federal cost share if they are
billed as administrative costs (as opposed to benefits). For
childless adults, the rate is generally 50 percent.
PRIOR VOTES :
Assembly Health: 14- 5
Assembly Appropriations:12- 5
Assembly Floor: 52- 24
COMMENTS :
1.Author's statement. More than 40 percent of Californians speak
a language other than English at home. Almost 7 million
Californians are estimated to speak English "less than very
well." 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. Today, language assistance in medical
settings is provided by trained or untrained staff or in an
informal manner by family members or friends. 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.
2.Enhanced federal matching funds for translation and
interpretation services. The Children's Health Insurance
Program Reauthorization Act (CHIPRA), Public Law 111-3,
enacted on February 4, 2009, contains provisions that affect
both CHIP and Medicaid. In July 2010, the Centers for Medicare
and Medicaid Services (CMS) provided guidance on the
implementation of Section 201(b) of CHIPRA, which provides
increased administrative funding for translation or
interpretation services provided under CHIP and Medicaid.
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Under Medicaid, increased federal funding for translation and
interpretation services available under CHIPRA is limited to
children and family members of those children. Under 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 is typically
50 percent in California for Medi-Cal and 65 percent for the
Healthy Families Program).
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 federal match for translation or interpretation
services differs for Medicaid and CHIP. For Medicaid, the
increased match is 75 percent of allowable expenditures. For
CHIP, the increased match is 75 percent, or the state's
enhanced FMAP plus 5 percent, whichever is higher (in
California, it would be 75 percent). However, the increased
federal match 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 percent for Medi-Cal and 65
percent for CHIP). In addition, the expenditures that qualify
for the increased match under CHIP are subject to the 10
percent cap on administrative expenditures.
3.Federal anti-discrimination law. Title VI of the Civil Rights
Act of 1964 and its implementing regulations provide that no
person shall be subject to discrimination on the basis of
race, color, or national origin under any program or activity
that receives federal financial assistance. Each federal
department has a civil rights office that is charged with
ensuring that its programs are free of discrimination. The
federal Department of Health and Human Services (HHS) Office
for Civil Rights (OCR) responsibilities include enforcing the
Civil Rights Act, the Americans with Disabilities Act, and the
Age Discrimination Act. Any organization or individual who
receives monies through HHS-health departments, health plans,
social service agencies, nonprofits, hospitals, clinics, and
physicians-is subject to OCR oversight. The OCR has the
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authority to investigate complaints related to linguistic
barriers, to initiate its own reviews, and to withhold federal
funds for noncompliance.
4.OCR policy guidance. CMS issued a State Medicaid Director
letter on August 31, 2000, that informed states of the policy
guidance that the OCR had issued on the prohibition against
national origin discrimination as it affects persons with LEP,
pursuant to Title VI of the Civil Rights Act of 1964.
OCR Policy Guidance requires recipients of federal assistance to
take reasonable steps to ensure meaningful access to their
programs and activities by LEP persons. The Guidance explains
that the obligation to provide meaningful access is
fact-dependent and starts with an individualized assessment
that balances four factors: (1) the number or proportion of
LEP persons eligible to be served or likely to be encountered
by the program or grantee; (2) the frequency with which LEP
individuals come into contact with the program; (3) the nature
and importance of the program, activity or service provided by
the grantee/recipient to its beneficiaries; and (4) the
resources available to the grantee/recipient and the costs of
interpretation/ translation services. CMS states there is no
"one size fits all" solution for Title VI compliance with
respect to LEP persons, and what constitutes "reasonable
steps" for large providers may not be reasonable where small
providers are concerned.
5.Data on language in California. According to the US Census
Bureau 2010 American Community Survey, 43.7 percent of
Californians over the age of 5 speak a language other than
English, and 19.9 percent of Californians over the age of 5
speak English "less than very well." According to the
California Health Interview Survey, of the 3.5 million adults
in the Medi-Cal program, about 281,000 (8.1 percent) had
difficulty understanding their doctor and/or needed another
person to help them understand their doctor. Among the parents
of 1.8 million children under age 12 in the Medi-Cal program,
about 135,000 (7.4 percent) had difficulty understanding the
child's doctor and/or needed another person's help to
understand the doctor.
6.Prior legislation. SB 442 (Calderon) of 2011 would have
required general acute care hospital policies for the
provision of language assistance to patients with language or
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communication barriers to include procedures for discussing
with the patient any cultural, religious, or spiritual beliefs
or practices that may influence care, and to increase the
ability of hospital staff to understand and respond to the
cultural needs of patients. Would have required hospitals'
policies on language assistance services to include criteria
on proficiency similar to those that apply to health plans. SB
442 was vetoed by the Governor.
SB 1405 (Soto) of 2006 would have required the Department of
Health Services (now DHCS) to create the Task Force on
Reimbursement for Language Services, as specified, to develop
a mechanism for seeking federal matching funds from CMS to pay
for language assistance services, as specified. SB 1405 was
placed on the inactive file.
AB 800 (Yee), Chapter 313, Statutes of 2005, requires all
health facilities (hospitals, skilled nursing facilities,
intermediate care facilities, correctional treatment centers)
and all primary care clinics to include a patient's principal
spoken language on the patient's health records.
SB 853 (Escutia), Chapter 713, Statutes of 2003, requires the
Department of Managed Health Care and the California
Department of Insurance to adopt regulations to ensure
enrollees have access to language assistance in obtaining
health care services.
7.Support (prior version). Western Center on Law & Poverty
states this bill would assist California in drawing down
additional federal funds for the interpreter services Medi-Cal
providers and plans are required to provide. While Medi-Cal
managed care plan rates include funds for interpreter services
and some providers draw down federal funds for language
services (such as hospitals), California is leaving federal
dollars on the table that it could use to provide these
critical services.
The American Federation of State, County and Municipal
Employees, AFL-CIO (AFSCME) 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. AFSCME states that, during these
difficult fiscal times, the state should seek to maximize all
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federal dollars to help the Medi-Cal program, and matching
funds for health care interpretation will help our state
respond to the needs of LEP Californians.
Health Access California writes in support that professional
interpreters trained in medical interpretation are critical as
medical terminology is not readily translated, cultural
sensitivity is lost, and avoidable medical errors occur.
8.Opposition. The Department of Finance (DOF) is opposed to the
prior version of this bill for the following reasons:
a. The bill would result in a General Fund cost of at
least $12.5 million.
b. It is unclear to what extent access to
interpretation services are insufficient in the current
Medi-Cal program.
c. This bill is unnecessary because managed care plans
provide access to interpreter services. To become a
contracted managed care provider, the contract stipulates
that the plan must provide 24-hour access to
interpreters. Managed care is in 30 counties with a
planned expansion to the remaining 28 counties that are
currently fee-for-service (FFS).
d. This bill is further unnecessary because a
significant number of FFS Medi-Cal beneficiaries are
provided interpreter services by the Health Care
Interpreter Network (HCIN). HCIN consists of 18 hospitals
and large medical centers throughout the state. HCIN
provides 130,000 interpreting sessions per year. The
number of HCIN member hospitals has gradually increased
since its implementation in 2005. Since July 2010, four
hospitals have joined HCIN.
9.Amendments. This bill was significantly amended on the Senate
Floor and re-referred to Senate Health Committee pursuant to
Senate Rule 29.10. The author is proposing amendments to this
bill related to collective bargaining for CCMIs and other
provisions. In order for this bill to be amended according to
Joint Rule 61(b)(16), it has to be heard by this Committee by
August 23, 2012, in order for the amendments to be adopted.
The amendments would do the following:
a. Require the exclusive representative of CCMIs and a
recognized nonprofit to partner to create and administer a
training program for medical interpreters in order to
prepare medical interpreters for the exam or other
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certification standards established for languages of lesser
diffusion, and to provide continuing education for those
CCMIs placed on the registry. Require a community advisory
committee to be established to make recommendations on
interpreter certification and services.
b. Require that the relationship of CCMIs to all parties
and recipients of service is one of independent contractor
unless otherwise specified by law.
c. Allow only interpreters certified under this bill to be
represented by the union for purposes of collective
bargaining authorized under this bill.
d. Require that, for purposes of the CommuniCal program,
CCMIs are not employees of the state, and requires CCMls to
be independent contractors of the state.
e. Prohibit, for the purposes of the CommuniCal program,
employees from being employees of the broker, health care
providers, or consumers.
f. Make the state action antitrust exemption to the
application of federal and state antitrust laws applicable
to the activities of CCMIs and their exclusive
representatives authorized under this bill or other
applicable law.
g. Require the base Medi-Cal reimbursement rate for CCMIs
to be no less than $60 per hour. Permit reimbursement to be
adjusted for factors such as geography, language spoken,
availability of interpreters, level of certification, and
travel time.
h. Require CCMIs to have the right to form, join, and
participate in the activities of a labor organization of
their own choosing for purpose of representation. Makes the
state action antitrust exemption to apply to federal and
state antitrust law applicable to the activities of CCMIs
and their exclusive representatives under this bill and
applicable law.
i. Require CCMIs to have the right to be represented by an
exclusive labor organization of their own choosing for the
purpose of collecting bargaining with the state of
California on matters of mutual concern, including but not
limited to, a list of ten specific provisions, including
development, maintenance and application of the registry,
the setting of reimbursements and rates for state-funded
medical interpreter programs.
j. Require the appropriate bargaining unit for CCMIs to be
a statewide unit of eligible CCMIs.
aa. Require a labor organization as referenced in this bill
to be a labor organization under a specified provision of
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the Internal Revenue Code which has as its primary purpose
the representation of public service providers in their
relations with state and other public entities.
bb. Require, upon request by a labor organization that is
signed by 20 percent of CCMIs, the certifying body to
furnish to the labor organization a list of all CCMIs,
including full names, telephone numbers, email addresses,
and mailing or home addresses within 5 days of the request.
cc. Require the Public Employment Relations Board (PERB),
upon application by petition, authorization cards, or union
membership cards of a labor organization adequately showing
that a majority of CCMIs in the state desire to be
represented exclusively be that labor organization and no
other, to certify and grant exclusive representation to the
labor organization. Require, if less than a majority but at
least 30 percent of CCMIs to be represented exclusively by
that labor organization, the matter to be set for a mail
ballot election.
dd. Require any representation election to be a mail ballot
election.
ee. Establish requirements for a preelection conference
between the state and the labor organization, prohibits
other labor organizations from be allowed to intervene in
an election unless the intervening labor organization shows
at least 30 percent of the CCMIs desire to be represented
exclusively by the intervening labor organization, and
require PERB to initiate a mail ballot election.
ff. Require a labor organization certified by PERB as
receiving a majority of all valid votes cast to be the
exclusive representative of all CCMIs in the state, and
requires all CCMIs who are eligible for the bargaining unit
after the certification to be part of the bargaining unit
and represented by the labor organization.
gg. Require discussions and collective bargaining between
the certified labor organization and the state and its
designated agents in DPA and DHCS to commence within 30
days upon certification and at any time thereafter upon
request of the labor organization.
hh. Establish requirements for agreements resulting from
collective bargaining, and for dues or service fee
reductions, and fair share service fees.
ii. Require the state, through its designated agents in DPA
and DHCS, to meet and collectively bargain in good faith
with representatives of a certified labor organization and
to fully consider the proposals made by the labor
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organization on behalf of CCMIs.
jj. Prohibit the state from interfering with, intimidating,
restraining, coercing or discriminating against CCMIs due
to the exercise of their rights, and requires a complaint
alleging a violation of this provision to be processed as
an unfair practice charge.
aaa. Permit any charging party, respondent or intervenor
aggrieved by a final decision or order of PERB in an unfair
practice case to petition for a writ of extraordinary
relief from that decision or order.
bbb. Require that execution of a valid written agreement
between the state and the certified labor organization to
bar the filing of an application or petition for
certification of a majority representative for the length
of the agreement except as otherwise provided in this bill.
ccc. Prohibit the state from encouraging or discouraging
membership in a labor organization or discriminating
against any CCMI on specified basis, including, but not
limited to, union activity, union membership, age, sex,
race, or religious beliefs.
ddd. Permit the state to adopt reasonable rules and
regulations after consultation in good faith with
representatives of a certified labor organization for
administration of CommuniCal Certified Medical Interpreter
relations under this bill.
10.Policy issues.
a. Certifying body for CCMIs. This bill requires SPB to
serve as the CCMI certifying body. The Governor's
Reorganization Plan 1 (GRP 1) consolidated SPB and the
Department of Personnel Administration into a single agency
known as the California Department of Human Resources.
Prior to the consolidation of the SPB and DPA into the new
California Department of Human Resources, SPB was charged
with providing testing for administrative hearing and
medical examination interpreters as well as maintaining and
publishing a list of interpreters to be utilized by the
departments when needed. While under SPB's purview, SPB
contracted with Cooperative Personnel Services (CPS) to
administer the examination at a cost that eventually
escalated to $250,000 a year. SPB indicates when it could
no longer afford the program in 2008, it canceled its
contract with CPS and took over the role of simply
maintaining the list of interpreters by collecting renewal
fees and providing the list to departments on a yearly
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basis. The current fee for renewal is $100 per year. SPB
indicates a test has not been administered since 2008 and
the list of interpreters remains the same assuming the
individuals on the list annually renew their registration
fees. Should this bill become law, follow-up legislation
will be needed to shift the requirements of this bill to
the California Department of Human Resources.
b. Potential cost shift to state. This bill requires
CommuniCal to offer medical interpreter services to
Medi-Cal providers serving Medi-Cal beneficiaries on either
a fee-for-service or managed care basis. The services
provided in this bill may increase the availability and
improve the quality of language services to Medi-Cal
enrollees, but it also would encourage a significant cost
shift from private providers, who are currently required to
provide these services under federal law and/or managed
care plan contracts, to the state. For example, DHCS
requires Medi-Cal managed care plans to provide interpreter
services on a 24-hour basis as part of their requirement to
comply with Title VI of the federal Civil Rights Act and
are reimbursed by Medi-Cal for this purpose. How will the
state ensure that it is not reimbursing CCMI providers and
health plans for providing interpretation services to
Medi-Cal managed care enrollees?
c. Removal from registry. This bill permits the certifying
body to remove the name of a person from the registry if
the person is deceased, the person notifies the SPB that
the person is unavailable for work, or the person does not
submit a required registry and certification fee or renewal
fee. Should failure of a CCMI to meet quality standards and
medical interpretation certification requirements adopted
through regulation also be grounds for removal from the
registry?
d. Quality standards. This bill requires the certifying
body to adopt quality standards and medical interpretation
certification requirements through regulation. Staff
recommends an amendment that the standards include, but not
be limited to, maintaining patient confidentiality and
familiarity with or experience working with medical
terminology.
SUPPORT AND OPPOSITION :
AB 2392 | Page 16
Support (prior version):American Federation of State, County and
Municipal Employees
California Academy of Family Physicians
California Communities United Institute
California Healthcare Interpreting
Association
California Optometric Association
California Pan-Ethnic Health Network (in
concept)
Children Now
Children's Defense Fund - California
The Children's Partnership
Congress of California Seniors
Disability Rights California
Health Access California
Latino Coalition for a Healthy California
National Association of Social Workers -
California Chapter
Western Center on Law and Poverty
Oppose (prior version):Department of Finance
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