Language Access Plan

Direct In-Language Communication#

HCAI’s Workforce Development Program has the capacity to provide direct Spanish language communication with the public upon request, through a certified bilingual staff person. Only certified bilingual staff are permitted to communicate with the public in languages other than English.

Certifying Bilingual Staff#

Per HCAI’s Bilingual Services Policy, designated bilingual positions and bilingual testing are implemented in compliance with Government Code Section 7292. A CalHR-designated bilingual position is one in which the incumbent uses bilingual skills on a continuous basis, an average of ten percent (10%) or more of the time, whether in a conversational, interpretation, or translation setting. HCAI is required to employ enough qualified bilingual persons in public contact positions. At this point, HCAI has identified the need for a Spanish-speaking, qualified bilingual position in our Office of Health Workforce Development.

Upon approval of a designated bilingual position, the EEO Office will schedule and coordinate the language proficiency testing and communicate test date(s) and times with the employee. Language proficiency testing to certify employee(s) in a designated bilingual position and/or job applicants offered employment in a designated bilingual position with HCAI is provided by the Los Angeles Unified School District (LAUSD) or other approved testing authority. The two-part language tests (oral and written) are conducted virtually and in-person. HCAI pays the cost of the language testing to certify employees in a designated bilingual position and for selected qualified job applicants for a bilingual-required position who have received a tentative job offer pending completion of language testing and bilingual proficiency certification.

HCAI’s process for certification of bilingual staff aligns with CalHR Human Resources Manual, Section 1003 – “Language Proficiency Scoring – Bilingual Position Qualification.

Interpretation#

For on-demand telephonic interpretation services, HCAI staff use the CalHHS On-Demand Interpretation Dial-In process housed at the California Department of Social Services (CDSS). When a non-English-speaking member of the public calls HCAI, HCAI asks the caller what language they speak and asks them to hold for language services support. Members of the public must be able to express their language preference in English or in a way that HCAI staff can understand in order to access the necessary services. HCAI staff will then follow the established process to arrange telephonic on-demand interpretation services.

HCAI staff most likely to receive calls from non-English speaking members of the public have been trained on this process and provided with a copy of the instructions to keep on hand.

For scheduled interpretation services, including ASL interpretation services, such as complying with a request provided in advance to interpret an HCAI public meeting, HCAI Program staff complete the CDSS Request for Interpretation/Translation Services form and, submit requests along with any necessary documents to languageservices@hcai.ca.gov one month in advance. HCAI has three authorized representatives, one of whom reviews the request for clarity and completeness before forwarding it to CDSS to schedule interpretation services. CDSS notifies the requester and the authorized representative when interpretation services have been arranged.

HCAI can provide interpretation services for urgent requests with much shorter notice by using its own language services contracted vendor. The Program staff completes the contracted vendor Request for Interpretation/Translation Services form and informs the EEO Office of the need for expedited scheduling. The EEO Office will then submit the interpretation requests to HCAI’s contracted vendor and share the interpreter’s contact information with the requesting HCAI program. HCAI also uses its vendor to regularly provide interpretation services to Spanish-speaking members of the public for HCAI-sponsored Health Care Affordability Board Meetings under HCAI’s Office of Health Care Affordability.

The language interpretation, including ASL, request process is outlined in HCAI’s Bilingual Service Policy and the EEO site. It is also regularly shared with HCAI Programs.

Translation#

The process for translation services, including ASL video clip services, is similar to that for interpretation services. HCAI Program staff complete the CDSS Request for Interpretation/Translation Services form and, submit it along with any necessary documents to languageservices@hcai.ca.gov one month in advance. One of HCAI’s authorized representatives will review the request for clarity and completeness before forwarding it to CDSS to schedule translation services. CDSS will return the completed translation to the requester and the authorized representative.

CDSS can provide translation services requested within a shorter timeline, but the deadline must be clearly communicated in the form. If CDSS is unable to meet an expedited deadline, HCAI can provide translation services for urgent requests through its contracted language services vendor. The Program staff completes the contracted vendor Request for Interpretation/Translation Services form and informs the EEO Office of the need for an expedited deadline. The EEO Office will then submit the translation request to HCAI’s contracted vendor.

The language translation, including ASL video clip, request process is outlined in HCAI’s Bilingual Service Policy and the EEO site. It is also regularly shared with HCAI Programs.

• Plain Language Standard for Translated Materials: Meaningful language access requires more than just translation. Documents that are dense, technical, or written using bureaucratic language may remain inaccessible even when translated into a person’s preferred language or provided via ASL. To ensure translated materials are understandable and usable, all vital documents and essential website content must be written in plain language prior to translation or ASL interpretation.
  HCAI requires that vital documents and essential website content be written at or below an 8^th-grade reading level before being submitted for translation. This standard supports accessibility for individuals with limited English Proficiency (LEP), individuals with lower literacy levels, and Deaf and hard-of-hearing individuals who use ASL. Clear source text also improves the accuracy and effectiveness of translated documents and ASL video content.
• Identification of Vital Documents for Translation: To identify which documents HCAI should translate into the top five non-English threshold languages, HCAI utilizes the five-factor analysis described previously.

HCAI analyzes the following:

1. Number or proportion of LEP persons eligible to be served or likely to be encountered by the program or service.
2. The frequency with which LEP individuals come into contact with the program or activity.
3. The nature and importance to people’s lives of the program or activity provided by the covered entity.
4. The significance of communication to an individual’s ability to access or be served by the program or activity; and
5. The resources available to the covered entity.

Program staff and HCAI’s Language Access Coordinators review HCAI’s programs to identify which program areas provide direct services to the public and which public meetings have received regular requests for interpretation services. In these program areas, which for HCAI include the Hospital Fair Billing Program, several workforce scholarship programs, the Office of the Patient Advocate, and the Office of Health Care Affordability, staff and coordinators conduct the five-factor analysis on program documents/materials intended for the public. HCAI translates the identified vital documents into the top five threshold languages, as outlined in the CalHHS Language Access Policy.

Identification of Vital Documents in HCAI’s Program Areas for Translation

• Hospital Fair Billing Program: The HFBP ensures that uninsured and underinsured individuals with family incomes at or below 400% of the federal poverty level receive financial assistance for medical services provided in licensed hospitals. It also ensures that proper debt collection practices are followed. This program is essential for supporting those already facing financial challenges and encourages individuals to seek necessary medical care rather than avoid it due to concerns about accumulating medical debt.

According to the Migration Policy Institute, one-third of immigrants in the United States are under 200% of the federal poverty level. With this information, it is reasonable to conclude that a significant number of LEP individuals are below 400% of the federal poverty level and may be eligible for HFBP services. After a full year under HCAI, the HFBP has regularly used language services to handle complaints filed in many languages.

The HFBP adheres to the Medi-Cal threshold language list established by the Department of Health Care Services (DHCS). This is important because both programs serve similar populations: low-income California residents. The languages identified by DHCS for Medi-Cal reflect those that meet the 5% threshold in each county.

The HFBP documents below have been identified as vital documents through the five-factor analysis and translated into the following languages: Spanish, Arabic, Armenian, Chinese, Farsi, Filipino, Hindi, Hmong, Japanese, Khmer/Cambodian, Korean, Lao, Mien, Portuguese, Punjabi, Russian, Tagalog, Thai, Ukrainian, Vietnamese.

• Patient Complaint Form
  • Authorized Representative Form
  • Release of Information Form
  • Hospital Bill Complaint Program (HBCP) Fact Sheet

HFBP translates the above vital documents and any other HFBP information upon request into other languages.

• Office of Health Workforce Development (OHWD): The OHWD provides scholarships and stipends to individuals interested in pursuing training in allied health and other health professions, including LEP individuals interested in these fields. Some of the professions eligible for these scholarships/stipends include CHW/P/Rs and Home Health Aides, who may be non-English-speaking or LEP persons and may access their training or education in their primary language.

The target population consists of individuals seeking to enter the health workforce who require financial support to pursue their training or education. According to the Migration Policy Institute, approximately 18% of healthcare workers are immigrants, with foreign-born individuals making up 40% of home health aides. Additionally, Latinas are highly represented in the CHW/P/R workforce. LEP students will typically interact with this program or service once a year during the scholarship application cycle, and then to verify their compliance with any commitments associated with receipt of the scholarship or stipend.

For any program where LEP individuals are eligible to receive a scholarship or stipend to complete their education to join the health workforce, the following document types are vital documents:

• The Application
• HCAI-Scholarship-Cost-of-Attendance-Form
• Scholarship-Program-Verification-SPV-Form
• Conflict-of-Interest-Letter-Examples-Template
• Program Grant Guide
• Grant Guide Addendums
• Technical Assistance Guide
• Program FAQ
• Outreach materials
• Webinar recordings

Vital documents are translated into the top five threshold languages (Spanish, Chinese, Tagalog, Vietnamese, Korean) required by the CalHHS Language Access Policy. The OHWD will translate the above vital documents and any other Program information upon request into other languages.

• The Office of the Patient Advocate (OPA): Publishes annual Report Cards rating health care organizations based on the quality of medical care and patient experience. The Report Cards provide consumers with information to support decision-making when accessing care. Consumers concerned about the quality of health care organizations when seeking medical care will typically interact with the program once a year.

According to the US Census Bureau (2015), almost 44% of California households speak a language other than English, and nearly seven million Californians (19%) report speaking English “less than very well.” Some percentage of these LEP households and Californians could seek information on the quality of health care organizations prior to seeking medical care. To adequately serve these consumers, the following content is considered vital or essential:

• The Health Plan Report Card, which includes information on the 12 largest health maintenance organizations and preferred provider organizations.

Vital documents / essential website content are translated into the top five threshold languages (Spanish, Chinese, Tagalog, Vietnamese, Korean) required by the CalHHS Language Access Policy. The Report Card will be translated into the top five threshold languages when this content is migrated to HCAI’s website sometime in 2026. The OPA will translate the Report Card and any other Program information upon request into other languages.

• CalRx Initiative under HCAI’s Office of Health Care Affordability: The purpose of the CalRx Initiative is to make medications more affordable for all Californians. CalRx offers Californians prescription drugs at low-cost, transparent prices by breaking down market barriers to affordable prescription drugs. To inform the public, the following content has been identified as vital:

• CalRx Insulin Fact Sheet
• CalRx Naloxone Fact Sheet

Vital documents / essential website content are translated into the top five threshold languages (Spanish, Chinese, Tagalog, Vietnamese, Korean) required by the CalHHS Language Access Policy. The Office of Health Care Affordability will translate other Program information upon request into other languages.

Identification of Essential Web Content for Translation

The CalHHS Language Access Policy defines “essential public website content” as (1)one or more introductory web pages having basic information about the CalHHS Department and its programs; and (2) non-English language taglines in the threshold languages and ASL advising of the availability of free oral interpretation services and written translations of English-language content.

Based on this definition, essential website content for HCAI is identified as the information on the HCAI home page, including: About Our Organization, HCAI Program Areas, and Important (Vital) Documents. HCAI’s essential website content has been translated into the top five threshold languages in separate webpages in Spanish, Chinese, Tagalog, Vietnamese, and Korean, and an ASL video clip with this content has been posted on HCAI’s website, per the CalHHS Language Access Policy. The translated webpages inform program participants that they can request additional translation and interpretation services at no cost.

The HFBP Patient Complaint Portal webpage has been translated and is available in Spanish and the Patient Complaint Form is available in 21 different languages that can be downloaded from HCAI’s website and submitted to the HFBP by mail. The HFBP webpage informs program participants that they can request additional translation and interpretation services at no cost in multiple languages.

The CHW/P/R Program webpage has been translated and is available in Spanish. 17 bilingual taglines (Arabic, Armenian, Cambodian, Chinese, Farsi, Hindi, Hmong, Japanese, Korean, Laotian, Mien, Punjabi, Russian, Spanish, Tagalog, Thai, Vietnamese) are accessible on the CHW/P/R webpage notifying non-English speaking and LEP persons that services are available in languages other than English upon request.

When translating vital documents or essential website content, if machine or Artificial Intelligence (AI) translation tools are used at any point in the translation workflow, the resulting translations must be reviewed for accuracy and quality by a qualified human reviewer before finalization or before reaching its intended audience.

Unsolicited Written Communication in a Non-English Language: Any unsolicited written communication from LEP individuals in languages other than English is forwarded to the Language Access Coordinators. If the communication is in Spanish, bilingual staff will determine the request or ask HCAI’s Spanish-certified bilingual staff for assistance. If translation services
are necessary to understand the content, the coordinator will submit a CDSS Request for Interpretation/Translation Services form and follow the translation process described above.