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INTRODUCTION
Interpreter Services Program
This program supports healthcare providers in meeting their federally required obligation to provide language access for Limited English Proficient (LEP) persons by providing interpreter services, free of charge, for eligible Medicaid healthcare appointments and eligible Department of Social and Health Services (DSHS), and Department of Children, Youth, and Families (DCYF) social service appointments. Universal Language Service is HCA’s vendor, serving as the coordinating entity. Universal is responsible for implementing the Incident Resolution Process.
Quality Assurance
The State of Washington Health Care Authority (HCA) established the Incident Resolution Process (IRP) in 2014 to ensure high-quality interpreter services for Limited English Proficient (LEP) Washington residents when seeking services through Washington State agencies, and to assure effective management and stewardship of state and federal resources. The IRP is administered by the coordinating entity contracted to schedule all HCA, DCYF, and DSHS appointments requiring interpreting services.
Consistent with the Collective Bargaining Agreement (CBA MOU-1)) between Washington Federation of State Employees (WFSE) for Language Access Providers (LAP) and the HCA; the HCA welcomed the Union’s feedback to improve the process of comments about services provided by language access providers. This input includes, but is not limited to, how interpreters and the Union are notified of feedback made to the coordinating entity(s) regarding services provided by interpreters. The IRP is not subject to the CBA grievance process.
Feedback
Complaints as well as compliments can be submitted via Universal’s scheduling platform, phone, fax, mail, email, or the HCA Universal website. All feedback will be handled by Universal’s WeCare Program, which is dedicated to soliciting and receiving feedback from Authorized Requesters and Interpreters in order to improve the quality of HCA’s Interpreter Services Program. Interpreters will be notified immediately of any feedback that is received about them. Additionally, all feedback is tracked through Universal’s online platform and is accessible to each Interpreter and Authorized Requester.
Notification exception: Interpreters will not receive an email notification to provide a response for givebacks. However, givebacks within 24 hours with a valid reason will not count as an incident.
Who can give feedback? Interpreters and Authorized Requesters
What can they give feedback on? Providers and interpreters’ services
How can they submit feedback?* Phone, Fax, Mail, Email, HCA Universal Website, User’s Scheduling Platform (Interpreters / Providers)
What are some potential outcomes? Warnings on records, partial or full suspension, termination, or recognition
*Not all methods of feedback submission are available to all users
METHODS FOR SUBMITTING FEEDBACK
Low Severity – Classifies any violation against the WAC 388-03-50 (spoken language interpreters) or NAD-RID Code of Professional Conduct (sign language interpreters) that has minimal impact on the appointment, provider and/or LEP person.
Examples (including but not limited to):
Medium Severity – Classifies any violation against the WAC 388-03-50 (spoken language interpreters) or NAD-RID Code of Professional Conduct (sign language interpreters) that has a moderate impact on the appointment, provider and/or LEP.
Examples (including but not limited to):
High Severity – Classifies any violation against the WAC 388-03-50 (spoken language interpreters) or NAD-RID Code of Professional Conduct (sign language interpreters) that has a significant impact on the appointment, provider and/or LEP; including those that put the health and safety of all parties involved at risk.
Examples (including but not limited to):
Health and Safety violations will have an immediate 10-day Full HCA Job Restriction or longer, pending outcome of incident.
TRACKING INCIDENTS
Time Periods
Low incidents are tracked on a rolling 12-month time period. This means that incidents are removed from the interpreter’s record once that incident is 366 days old. These incidents do not disappear, and they stay in the system. Incidents that have reached the 366-day mark will not be used to apply any actions listed in the following chart. However, they may be reviewed, and action may be taken in the event a pattern of unethical behavior or some other concern is identified.
Medium incidents are tracked on a rolling 12-month time period. This means that incidents are removed from the interpreter’s record once that incident is 366 days old. These incidents do not disappear, and they are maintained in the system. Incidents that have reached the 366-day mark will not be used to apply any actions listed in the following chart. However, they may be reviewed, and action may be taken in the event a pattern of unethical behavior or some other concern is identified.
High incidents are tracked for the lifetime of the Interpreter’s contract. There is no rolling time period, and high severity incidents never fall off the interpreter’s record. These incidents are subject to immediate action, up to and including termination of the interpreter’s contract. All terminations resulting from a high severity incident are reported to DSHS LTC. This report will include all information from the Provider, contractor, State Agency and the Interpreter.
Decertification
All interpreter contract terminations must be reported to DSHS LTC as required by WAC 388-03-170. DSHS LTC will conduct a review of the circumstances and make a determination of whether the interpreter should be allowed to retain his or her credential(s), or whether the credential(s) should be revoked. DSHS LTC is the entity responsible for this decision. HCA and Universal do not make this determination.
STEPS IN THE RESOLUTION PROCESS
INCIDENT SCALE TABLES
Please note that ALL incidents of feedback, regardless of severity, will result in a system-generated email notification immediately going to the interpreter notifying them of the incident. Exception: There are no notifications sent for incidents resulting from 24-hour givebacks. Termination of Contract will only happen with direct authorization of the HCA Interpreter Services Program Manager.
Business Days: Monday through Friday, 8:00am to 5:00pm excluding Washington State recognized holidays.
Extenuating Circumstances: Death in the family; serious illness of family or self; incapacitation of self; fire or other form of destruction to immediate household family of self; an unanticipated event or difficulty beyond the Interpreter’s control, including reported inclement weather conditions. Some actions may require proof.
Feedback Notification: Interpreters will immediately receive a system-generated email of each incident (complaint) entered into their profile on the Interpreter Platform.
Formal Written Notice: Interpreters who accumulate four (4) Low Severity Incidents or one (1) Medium Severity Incident will receive a Formal Written Notice via email in the form of an Incident Report outlining the details of each violation. This document will also be forwarded on to the HCA Interpreter Services Program Manager.
Full HCA Job Restriction: Action taken as a consequence of Interpreter’s multiple violations or due to the severity of incident(s). Interpreter’s Platform will not show ANY HCA jobs nor allow the Interpreter to accept any HCA jobs. In addition, all HCA jobs with dates of service during the Restriction Period will be removed from their schedule.
Incident: A complaint reported by the Provider of an inappropriate action that violates the WAC 388-03-050 (spoken language interpreters) or the NAD-RID Code of Professional Conduct (sign language interpreters).
Interpreter Incident Report: A report of the detailed incident or action that resulted in a violation of the WAC 388-03-050 (spoken language interpreters) or the NAD-RID Code of Professional Conduct (sign language interpreters).
Invalid Reason: Such as, but not limited to: public road closure notices where two (2) or more days advance notice was given; forgot appointment; cancelled the wrong appointment; overbooked schedule; vacation; previous appointment ran long.
Partial HCA Job Restriction: Action taken as a consequence of an Interpreter’s multiple violations or due to severity of the incident(s). Interpreter’s Platform will not show ANY HCA jobs, nor allow the Interpreter to accept any new HCA jobs. HCA jobs that have already been accepted will remain on the Interpreter’s schedule.
Restriction Period: Period of time during which an Interpreter’s access to HCA Contract jobs may be limited in some capacity as a result of corrective action.
Severity Level: Capacity in which the violation of the WAC 388-03-050 (spoken language interpreters) or the NAD-RID Code of Professional Conduct (sign language interpreters) is measured.
Termination of Contract: An Interpreter may be suspended indefinitely from servicing the HCA/DSHS/DCYF contract following an investigation and finding of multiple incidents at any severity level.
Valid Reason: Such as, but not limited to: unexpected travel emergencies (i.e. short-notice road closures, traffic accidents, flat tires), illness or medical emergency of self or family; reports obstacles to practice per the WAC 388-03-50 (spoken language interpreters) or the NAD-RID Code of Professional Conduct (sign language interpreters); inaccurate or incomplete information given by the Requester; or other Extenuating Circumstances (see definition).
