SD22 - Coverage of Interpreter and Translation Services for Fee-For-Service Medicaid Recipients Progress Report


Executive Summary:
Senate Joint Resolution 122, agreed to by the 2004 General Assembly, directed the Virginia Department of Medical Assistance Services (DMAS) to develop coverage of interpretation and translation services for Medicaid eligible persons with limited English proficiency. SJR 122 included that a progress report on the coverage development, which is the purpose of this document, be submitted by the first day of the 2005 General Assembly session.

Virginia is home to over half a million foreign-born persons, some of whom have limited English proficiency and therefore face substantial challenges communicating with their health care professionals. These individuals and their health care providers have a vested interest in ensuring that patients have the tools to communicate effectively through interpretation and translation services. For those enrolled in Medicaid and the State Children’s Health Insurance Program (Virginia’s FAMIS program), the Office of Civil Rights of the United States Department of Health and Human Services has provided guidance that it is the state’s responsibility to ensure that enrollees with limited English proficiency have meaningful access to covered health care services. The Centers for Medicare and Medicaid Services (CMS) provided further guidance that federal financial participation is available for interpreter and translation services provided through the Medicaid and Children’s Health Insurance programs.

Over half of Virginia’s Medicaid population is enrolled in managed care organizations (MCOs) and are already required by contract to provide interpreter and translator services. Persons enrolled in Medicaid fee-for-service have access to these services for enrollment and transportation services; but not for medical services. Therefore, the fee-for-service population is the target of this resolution.

As a first step in seeking reimbursement for these services, DMAS is in the process of implementing a pilot project in Northern Virginia to cover interpretation and translation services through administrative claiming. Northern Virginia was chosen due to the large number of foreign-born individuals and the substantial interest of existing providers. As a result of the pilot, the agency expects to evaluate the coverage and reimbursement process to determine whether to expand the coverage statewide. The pilot is expected to be fully implemented by July 1, 2005.

Medicaid programs may reimburse interpreter and translator services through “administrative claiming”. While this method can be more complex initially to set-up, it allows for simplification of the billing process through the aggregation of billing information submitted quarterly. It differs from the reimbursement of medical services where the medical provider submits an invoice each time a service is rendered. Through administrative claiming, federal funds may be obtained based on project participants’ documented expenditures of non-federal public funds as of July 1, 2005 and later.

Over the next several months, implementation activities will be underway by DMAS and the participating organizations to facilitate the reimbursement process. One written interagency agreement needs to be reestablished and other agreements need to be supplemented. Specific steps need to be drafted and discussed as to the billing process.

Studies of persons with limited English proficiency receiving care in doctor’s offices and other settings have indicated deficiencies in the delivery of care. The lack of a common language has been identified as leading to situations such as where the patient defers necessary medical care or does not take needed medication. The availability of DMAS reimbursed interpreter and translator services can reduce these occurrences and lead to improved health status for the patient.