In Part 1 of this blog series, we discussed National CLAS Standard 5: Offer Communication and Language Assistance and learned that, at its heart, this standard requires offering interpreters and translated documents to Limited English Proficient and sensory impaired patients and caregivers. In Part 2, we examined Standard 6: Inform Individuals of the Availability of Language Assistance and learned the importance of both verbal and written notification in many languages. In Part 3, we looked at Standard 7: Ensure the Competence of Individuals Providing Language Assistance and the qualities to look for in professional medical interpreters. We now turn to Standard 8:
Provide easy-to-understand print and multimedia materials and signage in the languages commonly used by the populations in the service area.
This Standard takes us beyond just providing written notice of the availability of language assistance, addressing everything from those great little health brochures we all see in our doctors’ waiting rooms to the wayfaring signs that help us navigate the often-confusing hallways of a large hospital. The Section 1557 regulations do not directly address what documents should be translated – other than taglines – instead indicating that health care entities still need to comply with Title VI of the Civil Rights Act of 1964, prohibiting National Origin Discrimination, which forms the basis of this CLAS Standard.
Let’s take a look at the components of this standard to gain better understanding.
- Easy-to-understand: Imagine yourself in your primary care physician’s waiting room. In a rack you see this pamphlet: “Rhinorrhea and Frequent Epistaxis? We can help!” I’m sure you get the picture. Often, health materials are written at a level too high for the average patient to understand. “Easy-to-understand” means keeping the health literacy of your patient population in mind when creating materials. Wouldn’t this be a little better? “Runny Nose and Frequent Nosebleeds? We can help!” This same concept must be applied to non-English written materials, as well.
- Print and Multimedia Materials: So we know that print materials should be easy-to-understand, but what materials should be translated? Unfortunately, there is no cut-and-dry list. Rather, health care facilities should translate materials that are vital to the patient’s ability to access health care and make educated decisions about health care, whether in print or on the internet. Some examples[1] include:
- Legal/Administrative documents, like informed consents and financial documents.
- Clinical information, like prevention and treatment instructions.
- Education, health prevention and promotion, and outreach materials, like brochures, fact sheets, and pamphlets.
- Signage: Signage includes both wayfaring signs (“This Way to Patient Registration à”), as well as notices of rights and the availability of conflict and grievance resolution processes.
- Languages Commonly Used: There are around 350 languages spoken in the U.S. Imagine having every sign translated into 350 languages? I’m pretty sure every inch of wall and ceiling would be covered! Of course, this is not the expectation. Rather, the HHS Office for Civil Rights advises facilities to consider four factors:
- The number or proportion of LEP persons eligible to be served or likely to be encountered
- The frequency with which individuals with LEP persons need service
- The nature and importance of the program, activity, or service provided
- The resources available and the costs of interpretation/translation services. There is no one-size-fits-all solution, and what constitute reasonable steps for large providers may not be reasonable where small providers are concerned.[2] (A bit of a red flag on this fourth factor: very, very, very rarely will HHS consider cost when determining if appropriate language services were provided. Be cautious before relying on this factor.)
Determining which languages are “commonly used” in your facility or geographic region can pose its own, unique challenge. For more information on this topic, take a look at Vocalink Global’s White Paper, “Methods of Effective Communication: A Guide to Choosing the Right Medium of Interpreting.”
Thank you for joining me for this 4-part series on Four Ways to be CLASsy. Visit us at vocalinkglobal.com for more information about healthcare interpreting, translation, and efficiency auditing.
[1] This list is in no way intended to be comprehensive. Each health care facility must determine which print and multimedia materials are vital to a patient’s ability to access health care and make educated decisions.