CurrentHealthPartnersPolicy N/A

Language Assistance Plan (Limited English Proficiency / LEP)

Corporate policy describing HealthPartners' language assistance services and expectations for providing meaningful access to patients, members, and families who are LEP or Deaf/Hard-of-Hearing; applies to HealthPartners care delivery and health plan operations.

Policy Summary

PayerHealthPartners

PolicyLanguage Assistance Plan (Limited English Proficiency / LEP)

Policy CodePolicy N/A

Change TypeNo material changes

Effective DateN/A

Next Review DateN/A

Key ActionArrange or provide professional interpreter services (in-person, telephonic, or VRI) at no cost when needed and avoid using family or friends as interpreters except in limited exceptions.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

enterprise-wideaccountability

no costservices cost

annualdocument review

15+languages notice

12%MN non-English at home

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Provision and quality criteria for language assistance

HealthPartners provides meaningful access via multiple modalities and sets quality and competency expectations for interpreters and bilingual staff.

Services must be provided free of charge, be accurate and timely, and protect the privacy and independence of the individual with LEP.

Modalities

In-person qualified interpreters (employees or vendors trained in third-party/triadic interpreting).
Spoken-language telephonic qualified interpreter services for on-demand or infrequent languages.
Video Remote Interpreters (VRI) (iPads) provided by qualified interpreters when available.
Communication services for Deaf and Hard-of-Hearing persons including ASL interpreters, Certified Deaf Interpreters (CDI), written communication, adaptive equipment (e.g., VRI iPads), visual aids and TDDs.
Translation of documents using a qualified translator or translating agency.

Quality and competency requirements

Interpreters and agencies must demonstrate competency and meet training and performance expectations; new agencies selected via RFP and vendor selection criteria reflecting HHS and CLAS guidelines.
Spoken language interpreters should have demonstrated competency (certification encouraged, e.g., CCHI or National Board certifications), uphold professional code of conduct, be on the Minnesota Department of Health roster, be trained in HealthPartners-specific expectations and medical terminology, or otherwise demonstrate proficiency and appropriate orientation/training.
American Sign Language interpreters must have RID certification, uphold professional conduct, and meet training/competency expectations including medical terminology and cultural sensitivity.

Bilingual staff guidance

Bilingual providers/employees may communicate directly with patients but should not routinely act as third-party interpreters unless trained and competent in interpreting skills and aware of conflicts of interest.
Minors should not serve as interpreters.

VRI and audio remote requirements

VRI must provide real-time, full-motion video and audio over a high-speed connection with sharply delineated images large enough to display faces and clear, audible transmission without lags or interruptions; users must receive adequate training to set up and operate the technology.
Audio remote interpreting must provide a clear, audible transmission of voices and adequate training for users.

Exceptions and patient choice

May rely on an accompanying adult only in an emergency when a qualified interpreter is not immediately available, or if the individual specifically requests that person to interpret; an individual may not be required to arrange or pay for their own interpreter.
Acceptance of offered language assistance is not required; if declined, the offer and declination should be documented in the individual's file or record.

Do not rely on unqualified staff or family/friends to provide interpreting except as noted in limited exceptions; work with a qualified translator for written content.

Language assistance provision and monitoring criteria

HealthPartners provides interpreter services enterprise-wide and monitors needs and effectiveness through data collection, oversight, and established complaint and review processes.

Governance and oversight: The Interpreter Services Work Group (ISWG) provides enterprise-wide leadership, promotes required and best practices, and conducts oversight of spoken and ASL services.

Monitoring methods: Monitoring is accomplished through data collection, surveys, complaint investigations, regular review including annual executive updates, and community feedback.

Data collection: Collect race, language and country of origin at multiple touchpoints including the electronic medical/dental record, health plan member website, disease and case management contacts, Member Services, and CareLine; centralized systems (HCSS) capture interpreter use and complaints.

Complaint process: Members may file complaints with HealthPartners’ Civil Rights Coordinator, the Minnesota DHS LEP Coordinator, or the U.S. HHS Office for Civil Rights (Region V); contact details are provided.

Language Assistance Availability and Maintenance

Availability and dissemination

The Language Assistance Plan is made available in public areas of HealthPartners to staff, volunteers, contractors, and community members and includes links to federal and state language access resources and professional interpreter organizations.

Annual operational and data updates are performed by the Interpreter Services Work Group (revisions documented over time).

Provider Responsibilities and Operational Oversight

Prior Authorization

Provider obligations for arranging interpreter services — arrange/provide professional interpreter services (in-person, telephonic, VRI) at no cost; do not rely on family/friends

Providers must arrange and provide professional interpreter services (in-person, telephonic, and Video Remote Interpreting) without undue delay and at no cost to members, patients, and their families. When a patient or member has limited English proficiency (LEP) or is Deaf or Hard-of-Hearing, providers are responsible for identifying the need for an interpreter during interactions and ensuring meaningful access to care and services. Providers may not rely on minors, family members, or friends to serve as interpreters except when the patient/member refuses a professional interpreter after being informed of the right to one. Bilingual staff should not routinely act as third‑party interpreters unless they are competent in third‑party interpreting and there is no conflict of interest.

In-person qualified interpreters (employees or vendors) trained in triadic interpreting
Telephonic qualified spoken-language interpreter services for on-demand or rare languages
Video Remote Interpreting (VRI) when available, provided by qualified interpreters
Communication services for Deaf and Hard-of-Hearing persons including sign language and Certified Deaf Interpreters; written communication and adaptive equipment

Note

Interpreter services oversight and data collection — Interpreter Services Work Group leadership and multi-touchpoint data collection to identify needs

The Interpreter Services Work Group (ISWG) leads enterprise-wide oversight and promotes required, expected, and best practices for spoken and American Sign Language services. Monitoring of interpreter services occurs through multi-touchpoint data collection, surveys, complaint investigations, regular review (including annual executive updates), and community feedback to identify language needs and service gaps.

ISWG provides leadership and system-wide standards for equitable access
Data collection occurs across electronic medical/dental records, member website, Disease and Case Management contacts, Member Services, and CareLine interactions
Use collected data to identify needed languages and target interpreter resources

Note

Access to Language Assistance Plan and Resources — plan available in public areas to staff, volunteers, contractors, and community with federal links

The Language Assistance Plan and related resources are publicly available to staff, volunteers, contractors, and community members. Providers and staff should use the listed federal and organizational resources (e.g., HHS LEP guidance, CLAS standards, interpreter registries, and state demographic resources) to inform local practices and to access tools for assessment and planning.

Language Assistance Plan is available in public areas to staff, volunteers, contractors, and community
Links to federal guidance and tools: HHS LEP guidance, CLAS standards, LEP.gov planning tools
Local/state resources for population language needs and interpreter registries

Key Terms and Definitions

Limited English Proficiency (LEP) — definition of LEP individual

DefinitionAn individual with limited English proficiency (LEP) is a person whose primary language for communication is not English and who has a limited ability to read, write, speak, or understand English.

Regulatory basisLEP protections and requirements derive from ACA Section 1557 and Title VI, which require reasonable steps to provide meaningful access to LEP individuals.

Meaningful access componentsIncludes provision of oral language assistance or written translation that is free of charge and without undue delay to ensure accurate and effective communication.

Key terms and definitions for interpreter and language assistance services

BilingualA person with some degree of proficiency in two languages; high bilingualism is necessary but not sufficient to ensure interpreting competence.

Bilingual staffStaff who have demonstrated minimum linguistic proficiency and cultural responsiveness; if acting as interpreters they must also meet additional training/certification and documentation requirements (e.g., CHI, CMI, RID, 40 hours training, 8 hours CE annually).

InterpretingOral transfer of a message from source to target language, including modes such as consecutive, simultaneous, sight-translation, and summarization.

I Speak CardsCards that state in English and the target language: 'I need a (target language) interpreter.'

EncounterA communication event in which the services of an interpreter are required.

Deaf and Hard-of-Hearing population / ASL

US prevalence of hearing lossAbout 20% of US adults (approximately 48 million) report some degree of hearing loss.

Minnesota prevalenceAbout 20% of Minnesotans report hearing loss.

ASL includedAmerican Sign Language (ASL) is included among the non-English languages spoken by HealthPartners members and is listed among the top 15 non-English languages.

Members using sign languageHealthPartners demographic reporting includes ASL in the top non-English languages spoken by members (2025 data).

OpenPayer

Language Assistance Plan (Limited English Proficiency / LEP)

Language Assistance — Coverage and Quality Criteria

Provider Responsibilities and Operational Oversight

Key Terms and Definitions