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
- Scheduling Platform – Authorized Requesters may submit feedback via the scheduling platform (this is the preferred method for feedback relating to a specific job)
- Website – Authorized Requesters and interpreters may submit feedback via the HCA Universal website
- Email – Authorized Requesters and interpreters may submit feedback via email to WeCare@ulsonline.net
- Fax – Authorized Requesters and interpreters may submit feedback via fax at: 1 (877) 516-4347 or 1 (425) 454-3635
- Mail – Authorized Requesters and interpreters may submit feedback via mail at 929 108th Ave NE, Suite 710, Bellevue WA 98004
- Phone – Authorized Requesters and interpreters may be transferred via phone to WeCare to provide feedback at 1 (888) 462-0500
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):
- Provider reported Interpreter Late Arrival
- Job Give Backs less than 24 calendar hours before Start Time (without a valid reason)
- Interpreter left job earlier than scheduled End Time without Provider approval
- Interpreter did not interpret accurately, expressing the source language message in a thorough and faithful manner
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):
- Interpreter No Show (without a valid reason)
- Interpreter solicits their services to the LEP person, their family members or provider
- Interpreter expresses personal opinions; offers unwanted conversation
- Services an acquaintance, family member, or friend without disclosing the potential conflict of interest
- Interpreter requests the Provider to enter incorrect start and/or end times
- Interpreter engages in unsupervised discussions with the provider and/or LEP person
- Interpreter contacts the provider or the LEP person
- During an interpretation session, Interpreter uses a mobile device for any reason unrelated to current services
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):
- Transporting a known LEP person to or from appointments
- Interpreter requests money or favors from the LEP person or provider
- Interpreter passes their appointments to other Interpreters without Universal’s knowledge and approval
- Interpreter falsifies a job invoice
- Harassment to provider or the LEP person in a manner that creates a barrier to care and services
- Any violation to HIPAA, or to the Health and Safety of the LEP person, Provider, or facility staff
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
- Feedback is submitted to Universal by authorized requesters, Interpreters, or via the Universal call center staff.
- Once recorded, Interpreters are notified via email that they received feedback and details of the feedback are included in the notification.
- Interpreters have ten (10) business days to respond to Universal in writing in order to dispute or explain the situation.
- Once Universal receives the Interpreter’s response, any necessary follow up must be completed within twenty (20) business days. In order to verify the validity of the Interpreter’s response, WeCare may need to reach out to the Authorized Requester or some other entity. Interpreters must never contact the provider or the LEP person regarding the incident.
- Universal will notify the Interpreter of the investigation’s outcome and take any corrective action if warranted, according to the incident scale table.
- If feedback takes more than sixty (60) days to resolve with the provider, or the incident is unable to be validated with the provider, the incident will be removed from the Interpreter’s profile.
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.
