Communication is one of the most critical elements of good patient care, and without it, your providers won’t know the patient’s history, current complaint, or even their name. That’s one reason the government requires practices to offer free written and verbal translation services to limited-English proficiency (LEP) patients. If you don’t have a plan in place to accommodate your LEP patient population, you could face fines, penalties and court costs, so your best bet is to establish a program immediately to stay compliant.

Consider these five critical steps as you create your LEP patient strategy.

1. Identify Who Needs Language Assistance

Before you’re able to create a comprehensive LEP plan, you must first understand which patients require language assistance, and determine which languages your patients speak. You can do this in a variety of different ways, but a few options are:

• Have “I speak” language identification cards handy so your patients can easily identify their language option. The government offers free downloadable cards in 38 different languages so you don’t have to do the translation work during the identification process.
• Post notices in commonly encountered languages around your office to encourage LEP patients to identify themselves.
• Review patients’ previous records to pinpoint any notation from prior healthcare providers that may identify their language options.

Once you’ve completed step one, you’ll have a clear idea of which languages your patients speak, how many patients fall into each language category, and therefore how many translation services you’ll need for each language.

2. Establish How You’ll Provide Language Assistance

Your LEP plan should share information about the ways you’ll be providing your language assistance services. Consider the following when developing your strategy:

• Types of language services available. Do you have written documents on-hand, or will you work with a translation consultant to have them available on an as-needed basis? Will you have a language line operator contracted, or do you have employees who speak multiple languages?
• How staff can obtain those services. Do all team members know how to access LEP services?
• How to respond to LEP callers. What will you do if someone calls your practice and doesn’t speak English? Do you have a plan?
• How to respond to written communications from LEP patients. If an LEP patient emails your practice or writes something down, will you have a way to translate it and respond?
• How to respond to LEP individuals who have in-person contact with recipient staff. Is your LEP translation service only available to the doctor, or will everyone at your practice who encounters them be able to communicate?
• How to ensure competency of interpreters and translation services. What vetting process will you use to evaluate your translators?

You should be asking these questions as you develop your program so you are appropriately prepared for every scenario.

3. Train Your Staff

All of your staff members should understand their obligations to provide meaningful access to information and services for every LEP patient, so you should ensure they are properly trained. This may include informing them of your LEP policies and procedures, how to contact in-person and online interpreters, and how to onboard new LEP patients.

It’s up to you to determine which staff members should be trained, but your program should certainly include front desk staff members, patient navigators, nurses who take vitals and interact with patients, and providers.

4. Notify LEP Patients

You should let your patients know the free LEP services you’ll be providing and how they can access them. Notification can take many forms, but common options include:

• Posting signs at entry points and reception desks in languages that LEP patients understand.
• Stating in outreach documents (brochures, marketing booklets, etc.) that language services are available.
• Posting on your website that you provide translation services.
• Including information in your voicemail options that allows patients to press a certain button for information about language services.

5. Monitor and Update Your LEP Plan

Like almost everything else in a medical practice, your LEP plan requires consistent review and updating. You can’t simply create it and put it on a shelf. Staying on top of it will allow you to frequently evaluate whether your LEP patient populations have changed, which could require changes to your strategy.

Keep notes on how frequently you encounter particular LEP language groups, whether your existing program is working (and if not, where improvements could be made), whether your staff knows what to do when they encounter an LEP patient, and whether your current translation service contractors are performing well.

As you gather this information, you should be adjusting and disseminating your LEP plan accordingly, and training staff every time something changes.

Stay on the right side of the law by complying with the government’s translation requirements for medical practices by participating in the online training session, “Comply With New HHS Translation Requirements for LEP Patients.” During this one-hour session, attorneys Daphne Kackloudis and Ashley Watson will provide you with step-by-step advice so you don’t miss a beat.

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