including specialized terminology, which can be demonstrated by taking a language proficiency examination. As a note, we reference language rather than Sign “sign interpreter” below “American in recognition that some enrollees may need assistance in another Language” country’s sign language. RECOMMENDATION: Amend subsection (h)(vii) as follows: (vii) The cultural and linguistic skills, including languages spoken by provider’s the provider or by skilled medical interpreter at the office. To include a provider’s language skills in the directory, the provider must demonstrate provider’s he/she: is proficient and able to communicate all healthcare information accurately in the non-English language or sign language for which the provider will provide services in a non-English language or sign language; and possesses proficiency in the non-English language or sign language for which services will be provided including knowledge of: specialized healthcare terms and concepts in both languages; and any particularized vocabulary and phraseology likely to be used by the limited English proficient person or person needing a sign language interpreter, such as regional usages of terms; If a provider only has conversational capabilities in a non-English language or sign language, the provider may not list that language in the provider directory. We appreciate inclusion of the term medical as a method of “skilled interpreter” identifying providers who can offer language services in their offices. We suggest, however, that HHS provide some explanation of what either in this “skilled” means, section or in the definitions section. First, we would recommend changing to “skilled” To be an effective interpreter, an individual must possess the requisite “competent”. knowledge, skills and abilities. Skills alone are insufficient. For example, in surveying the healthcare interpreter field to develop its certification examination, the Certification Commission for Healthcare Interpreters () identified 6 active listening, “skills” (including retaining information in short term memory, note taking) but over 20 “knowledge” domains and 20 e.g., Job Task Analysis Study and Results, May 14, “abilities”. (See, CCHI, , at 10-11). An individual could meet the skills required to be an interpreter 2010, but not have the knowledge or abilities so using the term interpreter does not “skilled” sufficiently capture the requirements for an effective interpreter. Second, given the overall lack of understanding of the knowledge, skills and abilities required of healthcare interpreters throughout the healthcare arena, we recommend
including specialized terminology, which can be demonstrated by taking a language proficiency examination. As a note, we reference “sign language interpreter” below rather than “American Sign Language” in recognition that some enrollees may need assistance in another country’s sign language. RECOMMENDATION: Amend subsection (h)(vii) as follows: (vii) The provider’s cultural and linguistic skills, including languages spoken by the provider or by skilled medical interpreter at the provider’s office. To include a provider’s language skills in the directory, the provider must demonstrate he/she: is proficient and able to communicate all healthcare information accurately in the non-English language or sign language for which the provider will provide services in a non-English language or sign language; and possesses proficiency in the non-English language or sign language for which services will be provided including knowledge of: specialized healthcare terms and concepts in both languages; and any particularized vocabulary and phraseology likely to be used by the limited English proficient person or person needing a sign language interpreter, such as regional usages of terms; If a provider only has conversational capabilities in a non-English language or sign language, the provider may not list that language in the provider directory. We appreciate inclusion of the term “skilled medical interpreter” as a method of identifying providers who can offer language services in their offices. We suggest, however, that HHS provide some explanation of what “skilled” means, either in this section or in the definitions section. First, we would recommend changing “skilled” to “competent”. To be an effective interpreter, an individual must possess the requisite knowledge, skills and abilities. Skills alone are insufficient. For example, in surveying the healthcare interpreter field to develop its certification examination, the Certification Commission for Healthcare Interpreters () identified 6 “skills” (including active listening, retaining information in short term memory, note taking) but over 20 “knowledge” domains and 20 “abilities”. (See, e.g., Job Task Analysis Study and Results, May 14, 2010, CCHI, , at 10-11). An individual could meet the skills required to be an interpreter but not have the knowledge or abilities so using the term “skilled” interpreter does not sufficiently capture the requirements for an effective interpreter. Second, given the overall lack of understanding of the knowledge, skills and abilities required of healthcare interpreters throughout the healthcare arena, we recommend
Guide-to-proposed-Managed-Care-Rule.docx