Language Interpreter Services

In accordance with Minnesota Department of Human Services (DHS) contract requirements and PrimeWest Health Provider Participation Agreement requirements, all PrimeWest Health contracted providers must provide language interpreter services. This section of the PrimeWest Health Provider Manual, an attachment to the Provider Participation Agreement, includes details of these requirements.

1. Sign language interpreter services must be available when such services are necessary to help deaf or hard of hearing member get covered services
2. Foreign spoken language interpreter services must be available to all patients with LEP, whether or not the patient is a member of PrimeWest Health

PrimeWest Health covers sign and foreign spoken language interpreter service with the following conditions if the provider cannot communicate with the member:

1. Providers are responsible for arranging the interpreter service in a timely fashion and for paying the interpreter. Members may use a family member or friend as their interpreter; however, minor children may not be used as interpreters.
2. MHCP covers face-to-face spoken language interpreter services only when the interpreters are actively enrolled in the Minnesota Department of Health (MDH) Interpreter Roster. Providers, including those enrolled with PrimeWest Health, are responsible for verifying that face-to-face spoken language interpreters are enrolled in the roster. PrimeWest Health does not contract with or enroll interpreters. Providers must document the following in the member’s medical record:
   1. That an interpreter was used
   2. The date and time the interpreter was used
   3. The name of the interpreter and agency.
3. Three people must be present for the service to be covered: the provider, the patient, and the interpreter.
4. For sign language interpreter services, the interpreter may be on a video screen when using video remote interpreter services.
5. For foreign spoken language interpreter services, the interpreter may be on the phone.
6. Staff members at the provider’s office who are qualified in sign language or competent in foreign spoken language interpretation may interpret the medical service.
7. Minor children should never be used as interpreters. Providers may not require a patient to use a family member or friend as an interpreter. However, some people may feel more comfortable when a family member or friend acts as an interpreter.
8. Providers must initiate an offer to provide free and timely language assistance when patients and staff are having difficulty understanding each other or when patients ask for language (sign or foreign spoken) assistance.

PrimeWest Health also covers language interpreter services for the parent/guardian when the patient is a minor. In some cases, interpreter services need to be made available on an expedited/emergency basis.

Translating documents (paper to paper) is not a covered foreign spoken language interpreter service.

Quality Standards for Language Assistance Services

Providers have two ways to provide language assistance services: oral interpretation either in person or through a telephone interpretation service, including the use of bilingual staff and written translation. In some cases, language assistance services should be made available on an expedited/emergency basis.

Regardless of the type of language assistance provided, the services must be an accurate and quality service. For example, under the Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, an interpreter must be competent to provide interpreter services. Competent interpreters:

1. Demonstrate proficiency in both English and another language;
2. Use the appropriate mode of interpreting given the situation at hand (e.g., consecutive, simultaneous, summarization, or sight translation);
3. Have received appropriate interpreter training that includes instruction in the skills and ethics of interpreting and rules of confidentiality and/or data privacy;
4. Understand their role as interpreters without deviating into other roles, such as counselor or legal advisor;
5. Have fundamental knowledge in both languages of any specialized health care terms or concepts;
6. Are sensitive to the member’s culture; and
7. Understand and follow confidentiality and impartiality rules to the same extent as the staff person involved (refer to Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons).

Eligible Providers

All enrolled providers can bill for interpreter services except for the following:

1. Federally Qualified Health Centers (FQHCs) for Federally funded encounter rate recipients – included in the encounter rate
2. Inpatient hospitals – included in the inpatient hospital DRG payment
3. Nursing facilities – included in the per diem rate
4. Rural Health Clinics (RHCs) for Federally funded encounter rate recipients – included in the encounter rate
5. Transportation providers – the service of transporting a member; does not include interpreter service reimbursements

Using Minor Children or Family and Friends as Interpreters

Minor children should never be used as interpreters. Providers may not require an LEP person to use a family member or friend as an interpreter. However, some people may feel more comfortable when a family member or friend acts as an interpreter. Providers must initiate an offer to provide free and timely language assistance when patients are having difficulty communicating in English or when patients ask for language assistance. Although providers should not plan to rely on an LEP person’s family members, friends, or other informal interpreters to provide meaningful access to its services, providers should respect an LEP person’s desire to use an interpreter of his/her own choosing in place of the language services they offer. Providers may use a patient’s family member or friend as an interpreter in emergency situations (refer to Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons).

Sign Language Interpreters

DHS Deaf and Hard of Hearing Services Division (DHHSD) regional staff located throughout Minnesota can assist with questions about sign language interpreter referral services or hiring freelance sign language interpreters. Refer to the DHHSD and Sign Language Interpreter Referral web sites for additional information and resources. DHHSD can also be reached at 1-800-657-3663.

Oral Language Interpreter Services

Oral language interpreter services are a covered benefit for PrimeWest Health members. Providers must verify that the spoken language interpreter being used for covered face-to-face spoken language interpreter services is listed in MDH’s Spoken Language Health Care Interpreter Roster.

PrimeWest Health does not contract with or enroll interpreters. Continue to document interpreter information (such as name, agency, etc.). PrimeWest Health will only reimburse for provision of face-to-face oral interpretation services by interpreters who are listed on the MDH Roster.

Limited English Proficiency (LEP)

Federal law requires that providers who receive Federal funds must provide oral language interpreter services to all patients who have LEP at no cost to the patient, whether or not the patient is a member of PrimeWest Health.

In August 2003, the United States Department of Health and Human Services (HHS) published in the Federal Register its own Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons document designed to help human services providers understand the extent of their obligation to provide interpretation and translation services to LEP patients.

A patient has LEP when he/she is not able to speak, read, write, or understand English at a level that allows him/her to interact effectively with PrimeWest Health and/or county and provider agencies. Enrolled providers must take reasonable steps to provide effective oral language interpreter services when such services are necessary to enable any LEP patient to obtain medical services.

Reasonable Steps

To know what reasonable steps to take, the Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons instructs providers to start by conducting an individualized assessment that balances four factors:

1. The number/proportion of people with LEP eligible to be serviced or likely to be encountered by the provider;
2. How often people with LEP come in contact with the provider’s services;
3. The nature and importance of the services in people’s lives; and
4. The language assistance resources available to the provider and what it will cost to provide those services to the public.

The results of this four-factor analysis help the provider determine the mix of language assistance services it should provide. For example, in most cases, interpreter services will be the most effective type of language assistance available to patients. However, other forms of language assistance may be appropriate in certain situations, such as using translated application forms and other documents, or using bilingual staff members who are proficient in both English and a non-English language. The right mix of language assistance services should be based on what is both reasonable and necessary given the results of the four-factor analysis (refer to Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons).

Limited English Proficiency (LEP) Plan

PrimeWest Health strongly recommends that providers develop a written LEP Plan. An LEP Plan is a written policy and procedure that describes how the provider will offer free and timely interpreter and/or other language assistance services to communicate effectively with non- or limited-English speaking patients. An LEP Plan does not have to be lengthy or complicated. It may be as simple as being prepared to use a commercial telephone interpreter service or identifying bilingual staff members within the office who are proficient enough in both English and a non-English language to communicate directly with a patient in his/her primary language (refer to Summary of Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons).

The DHS LEP Model Plan (DHS-4210) can be used as a template for your LEP Plan.

Providers serving very few people with LEP or those with very limited resources may choose not to develop a written LEP Plan. However, all providers are responsible for providing meaningful access to services for their LEP patients and they must have a plan, written or not, to do so. Providers who decide to not develop an LEP Plan may want to consider alternative reasonable ways to show how they are providing meaningful access in compliance with Title VI. Should a complaint arise, all providers must be able to show intent to comply with the law and have documentation sufficient to show what happened in the particular case.

Interpreter Unit Authorizations

Submit an authorization request only after the allowed 8 units (1 unit = 15 minutes) of interpreter services per date of service have been used.

The prior authorization must include, but is not limited to, the following:

1. Name and provider number of the enrolled PrimeWest Health provider delivering the covered service that requires the additional interpreter service units
2. Name, date of birth (DOB), and PrimeWest Health member ID number requiring the additional interpreter service units
3. Service code or description of the service being provided requiring the additional interpreter service units
4. Brief explanation of why this service will require additional interpreter service units
5. Self-attestation by the provider that none of the interpreter service units include time or consideration for reimbursement for any of the following:
   1. Travel time
   2. Wait time (includes time waiting in the lobby, exam room, or any office space when a medical service is not being delivered)
   3. Mileage
   4. No-shows or cancellations
   5. Form translation activities
   6. Form completion activities
   7. Time when all three people required for interpreter services (provider, member, interpreter) are not involved in the discussion or delivery of the member’s covered service(s) provided during the appointment

Do not include the initial 8 units as part of the additional interpreter units being requested.

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Updated_12/30/2025