Providing high-quality language access services in the midst of this pandemic is crucial. Working with local agencies and local, credentialed interpreters protects patients and ensures that State revenue remains within Oregon, where earnings have dropped significantly. 

OHA Certified and Qualified interpreters must be prioritized for appointments in accordance with Oregon State Law and informed of policy changes that affect how CCOs pay for their services. 

OHA has long been a leader in language access. We hope that these 4 steps can be taken as part of OHA’s plan during this public health emergency:

1. Under a temporary administrative rule that OHA filed with the Secretary of State in response to COVID-19, CCOs are required to “reimburse contracted physical and behavioral health providers for covered services provided to OHP members by means of telemedicine at the same rate paid when such services are provided in person.” Interpreting services are covered by CCOs, but this administrative rule does not specifically mention interpreting services. 

We request that interpreting services be mentioned specifically, and that CCOs and their first-tier, downstream and related entities be required to pay Certified and Qualified interpreters providing remote interpreting services their on-site rates through 9/21/2020, since many CCOs do not contract directly with interpreters, but go through third-party companies called language service providers or agencies.  We request that OHA compile and include on its website a list of language service providers that are contracted with CCOs.

2. While CCOs were notified that OHA would file this administrative rule with the Secretary of State, interpreters registered with the Oregon Health Authority were not notified. 

We request that Certified and Qualified interpreters on the Oregon Health Authority registry be notified of this and any future changes to how CCOs will pay for interpreting services.

3. The administrative rule also requires CCOs to “ensure that all telemedicine services meet all requirements relating to language access, interpreter, and translation services set forth in OAR 410-141-3515(12).” However, OHA pushed back reporting requirements related to the provision of language access to patients facing language barriers. 

Due to the decreased volume of appointments with COVID-19,  finding available Certified and Qualified interpreters to meet patient needs on-site and with existing VRI and telephonic systems should be easier now than ever, and it should be a high priority in the midst of a situation where patients' access to high-quality language access services is crucial. One interpreting agency states that the amount of work available to interpreters has dropped by about 75%. Oregon has around 700 Certified and Qualified interpreters, accounting for less about 20% of the workforce of around 3500.  If Certified and Qualified interpreters were prioritized, they would have plenty of work--but that’s not the case.  

We request that OHA verify that Certified and Qualified interpreters are being prioritized during the COVID-19 pandemic, particularly for remote appointments, which are often assigned to uncredentialed interpreters based outside of Oregon. When credentialed interpreters are prioritized, they have enough work to stay in the profession, patients have access to the services they are entitled to by law, and state dollars stay in the local economy.

4. As providers that have not used telehealth in the past make the switch, it may be difficult to integrate interpreting services into the telehealth platform. Nevertheless, in requiring CCOs to comply with 410-141-3515(12), this administrative rule identifies the provision of language access services as a priority, and steps should be taken to ensure that language access services are available for visits that are switched from on-site to telehealth.

We request that OHA require CCOs to verify that their provider networks have integrated language access services into the telehealth systems they use during the COVID-19 pandemic.