Language Assistance Program and Cultural Competency

Riverside and San Bernardino County Medi-Cal providers must receive interpreter services through Molina Healthcare.

The Health Care Language Assistance Regulations require all health plans to provide language assistance and culturally responsive services to members with limited English proficiency (LEP), limited reading skills, who are deaf or have a hearing impairment, or who have diverse cultural and ethnic backgrounds. To comply with this requirement, Health Net created the Language Assistance Program (LAP). Health Net's LAP offers interpreter services to members to ensure that Health Net members with LEP are able to obtain language assistance while accessing health care services. Health Net's LAP supports Health Net members' linguistic and cultural needs. Additionally, Health Net offers interpreter support and requires all participating providers to take cultural competency courses. Providers are encouraged to take courses through the U.S. Department of Health and Human Services (HHS) Office of Minority Health (OMH) as part of their continuing education. For more information, refer to OMH Think Cultural Health.

Health Net participating providers must comply with Health Net's LAP as defined below.

Compliance Requirements

Health Net participating providers, including case management and utilization management (UM)-delegated providers, are required to support Health Net's LAP by using the following:

• Interpreter services - Use qualified interpreters for members with LEP. Interpreter services are provided by Health Net at no cost to providers or members. Telephone interpreters are available in more than 150 languages. Advance notice for telephone interpreters is not required.
• Translation services - Provide Health Net, upon request and in a timely manner, with the documents sent to members. If a Health Net member requests translation or an alternative format of an English document that was produced by a delegated PPG on Health Net's behalf, the provider must refer the member to the Health Net Member Services phone number listed on the member's identification (ID) card. When Member Services receives the request from the member, Health Net contacts the provider requesting a copy of the specific English document for translation or alternative format. The provider must submit the document within 48 hours of Health Net's request.
• Tagline and non-discrimination notice - Include a Health Net-specific tagline and non-discrimination notice with vital documents going to Health Net members.

• Member complaint/grievance forms - Provide translated member grievance forms (provided under the Forms section of the provider library) to members upon request.
• PPO member complaints - Inform PPO members that they can submit grievances verbally or in writing by contacting the Health Net Member Services Department using the contact information provided on the back of the member identification (ID) card.
• Independent Medical Review (IMR) Application - Locate translated IMR applications on the Department of Managed Health Care (DMHC) website at www.dmhc.ca.gov and make them available to members upon request.
• Medical record documentation - Document the member's language preference (including English) and the refusal or use of interpreter services in the member's medical record.

Interpreter Services

Health Net offers 24-hour access to interpreter services at no cost. To obtain interpreter services, members and providers can contact Health Net Member Services at the phone number located on the member's ID card. Telephone interpreters are available at the time of the appointment without prior arrangement. Allow adequate time before the appointment to get the telephone interpreter on the line.

Non-English interpreter services include:

• Qualified interpreters trained on health care terminology and a wide range of interpreting protocols and ethics.
• Telephone interpreters available in more than 150 languages and on short notice in support of last-minute appointments to meet the revised access and availability standards.
• Sign language interpreter services are available when requested a minimum of 10 business days in advance of the appointment.
• Support to address common communication challenges across cultures.
• Oral translations of member materials in more than 150 languages.

Provider Responsibilities

Participating providers must ensure that language services meet the established requirements as follows:

• Ensure that interpreters are available at the time of the appointment.
• Ensure that members with LEP are not subject to unreasonable delays in the delivery of services, including accessing providers after hours.
• Provide interpreter services at no cost to members.
• Extend the same participation opportunities in programs and activities to all members regardless of their language preferences.
• Provide services to members with LEP that are as effective as those provided to members without LEP.
• Record the language needs of each member, as well as the member's request or refusal of interpreter services, in their medical record. Providers are strongly encouraged to document the use of any interpreter in the member's record.
• Provide translated member grievance forms to members upon request.

Providers are prohibited from:

• Requesting or requiring an individual with LEP to provide their own interpreter.
• Relying on staff other than qualified bilingual/multilingual staff to communicate directly with individuals with LEP.
• Relying on an adult or minor accompanying an individual with LEP to interpret or facilitate communication except in the following scenarios:
• A minor or an adult accompanying the patient may be used as an interpreter in an emergency involving an imminent threat to the safety or welfare of the individual or the public where there is no qualified interpreter for the individual with LEP immediately available.
• An accompanying adult may be used to interpret or facilitate communication when the individual with LEP specifically requests that the accompanying adult interpret, the accompanying adult agrees to provide such assistance and reliance on that adult for such assistance is appropriate under the circumstances. Providers are encouraged to document in the member's medical record the circumstances that resulted in the use of a minor or accompanying adult as an interpreter.

Providers are responsible to provide translated care plans in threshold languages to members with LEP and/or their caretakers. Care plans must be written at a 6^th grade reading level for Medi-Cal and 8^th grade reading level for Commercial members. Health Net provides the translations in threshold languages upon request with documentation that the content is at the applicable reading level. Refer to the provider Interpreter Services Quick Reference Guide for assistance.

• Commercial and Medi-Cal Interpreter Services Quick Reference Guide (PDF)
• CalViva Health Interpreter Services Quick Reference Guide (PDF)
• Community Health Plan of Imperial Valley Interpreter Services Quick Reference Guide (PDF)

A Language Identification Poster is available to print and post in providers' offices.

• Commercial, Medi-Cal Language Identification Poster (PDF)
• CalViva Health Language Identification Poster (PDF)
• Community Health Plan of Imperial Valley Language Identification Poster (PDF)

For more information about how to work with an interpreter, refer to the Health Industry Collaboration Effort (ICE): Provider Tools to Care for Diverse Populations – Health Net (PDF), Health Industry Collaboration Effort: Provider Tools to Care for Diverse Populations – Community Health Plan of Imperial Valley (PDF) or Health Industry Collaboration Effort: Provider Tools to Care for Diverse Populations – CalViva Health Industry Collaboration Effort (PDF).

Cultural Competency Training

All Health Net participating providers must take cultural competency training. We suggest that you take one of the trainings offered by the Office of Minority Health (OMH). The trainings are computer-based training for health care providers. OMH developed these no-cost trainings to give providers competencies to better treat an increasingly diverse population. The general training is available at Think Cultural Health. OMH also has a no-cost, accredited maternal health care training available at Think Cultural Health Education. Health Net does not sponsor these trainings or materials.

The Institute for Healthcare Improvement has free downloads to improve plain language communication with patients under the Ask Me 3^® program.

You can also access Health Net’s cultural competency training for providers and PPG staff or contact Health Net's Health Equity Department for customized training to meet your needs.

Medi-Cal providers may have the completion of cultural competency training listed in the provider directory. The provider directory indicates a “Y” if the provider has completed two hours of cultural competency training within the last 24 months. Notify Health Net by email after completing the training at PSOps@healthnet.com. Include your practitioner’s name, a certificate of completion, the National Provider Identifier (NPI), and a statement that you have completed the training.

Providers who would like information aboutinterpreter services, cross-cultural communication, health literacy or to schedule a training, can contact Health Net's Health Equity Department.