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Administrative Policy on Limited English Proficiency

Scope

This policy applies to navigators and certified application counselors (CACs).

Terms and Definitions

Effective communication: Effective communication occurs when assisters have taken the necessary steps to make sure that a person with Limited English Proficiency (LEP) is given adequate information to understand the services and benefits available and receives the benefits for which the person is eligible. Effective communication also means that a person with LEP is able to communicate the relevant circumstances of their situation to the assister so the assister can do their job.

Interpreting: Interpreting means the oral or spoken transfer of a message from the source language into the target language.

Limited English Proficiency (LEP): A person with LEP is not able to speak, read, write or understand the English language well enough to allow them to interact effectively with health and social services agencies and other providers.

Meaningful access: Meaningful access to programs and services is the standard of access required of federally funded entities to comply with Title VI’s language access requirements. To ensure meaningful access for people with LEP, service providers must make available to applicants and recipients free and timely language assistance that result in accurate and effective communication.

Translation: Translation means the written transfer of a message from the source language into the target language.

Policy Details

To ensure individuals who are limited in their English language proficiency have meaningful access to MNsure program information and services.

Procedures for Limited English Proficiency

Assisters with any questions related to interpreting or translation for consumers with LEP should contact the MNsure Accessibility and Equal Opportunity (AEO) office. The AEO Office can be reached by email at AEO@mnsure.org, or by phone, by calling the MNsure Contact Center at 1-855-366-7873.

  1. If a client with LEP walks-in or calls your office, assisters should use the Language Line Solutions, as detailed below, to facilitate communication.
  2. If a client with LEP would like to make an appointment with you, and you are not qualified to help them in his or her preferred language, contact the MNsure Accessibility and Equal Opportunity (AEO) office ASAP. The AEO office can be reached by email at AEO@mnsure.org, or by phone, by calling the MNsure Contact Center at 1-855-366-7873. The AEO office will be able to help determine on a case-by-case basis the best way to accommodate an individual with LEP to ensure meaningful communication. This may include interpreting services, translation services, or referral services. Again, contact the AEO office ASAP.
  3. When receiving a call from a non-English speaker, use Conference Hold to place the non-English speaker on hold. When placing a call to a non-English speaker, start at step D.
  4. If an interpreter is needed, call the Language Line Solutions toll-free number – 1-800-367-9559.
    1. Enter the six-digit Client ID (Minnesota State Offices): 509052
    2. Press 1 for Spanish or 2 for all other languages (Speak the name of the language at the prompt). If you don’t know the language the caller speaks, press 0 and you will be transferred to an expert in language identification.
    3. Enter the six-digit Access code (MNsure’s Assister ID): 358459
    4. Add the non-English speaker to the line.
    5. Once the conference call is live, go ahead and start addressing the caller directly. While working with an interpreter please use the following parameters:
      1. Speak in short sentences and pause frequently to allow the interpreter to interpret what has been said. Give the interpreter time to finish before speaking again.
      2. Check for client understanding. Ask the client to repeat back to you what you explained. Provide opportunities for clarification. You may ask the client with LEP “Tell me what you understand?’, rather than “Do you understand?” or “Does it make sense?”.
      3. When the conversation is completed, thank both the client and the interpreter and say “Interpreter, end of call” and the call ends.
  5. Document working with the interpreter in the client’s case file or keep appropriate records when you work with an interpreter.
  6. When working with a consumer who uses American Sign Language (ASL), follow the procedures in section 4(B) of this Policy. Language Line Solutions does not include ASL interpreters because it is a visual language. However, consumers who use ASL may call you using their preferred telecommunications relay provider. Direct any questions you may have to the MNsure AEO office.

Helpful Hints for Working with Telephone Interpreters

  • Tell the interpreter the purpose of your call in less than 20 seconds (briefing). Describe the type of information you are planning to convey or you may need.
  • Enunciate your words and do not use contractions, which can be easily misunderstood as the opposite of your meaning, e.g., “can’t –cannot.”, “won’t –will not”.
  • Speak in short sentences, expressing one idea at a time.
  • Speak in a normal speech speed. Do not rush the conversation.
  • Avoid the use of double negatives, e.g., “If you don’t appear in person, you won’t get your benefits.” Instead, “You must come in person in order to get your benefits.”
  • Speak in the first and second person of the singular: I & You. Do not say “Can you ask her why she is calling today?” Instead you must address the client or caller directly: “Can you tell me the reason for you call today?” or “How may I help you?”.
  • Avoid using colloquialisms and acronyms, e.g., “MFIP.” If you must do so, please explain their meaning.
  • Provide brief explanations of technical terms, or terms-of-art to the caller or client, e.g., “Spend-down” means that you must spend or reduce some of your monies or assets in order to be eligible for services.”
  • Avoid using compound verbs such as use up, help out, hang on, and rather say “reduce,” “help,” “wait.”
  • Continue to ask the client or caller if the information makes sense or if the caller or client needs more explanation about items the client or caller cannot understand.
  • ABOVE ALL, BE PATIENT with the interpreter, the client and yourself!
  • Thank the interpreter for performing a difficult and valuable service.

General Information

  1. Language access will be paid for by MNsure; however, MNsure must preauthorize payment for language access services. This service is only to be used in performing the work of a assister. Please note that random audits of telephonic interpreting service billing may be conducted by MNsure.
  2. The Language Line Solutions service is charged on a per-minute basis.
  3. Assisters are not to work with family or friends as interpreters.
  4. While working with interpreters either face-to-face or over the phone, follow these rules:
    1. Always offer meaningful access either through a professional interpreter (face-to-face, over-the-phone, or by Video Remote Interpreting (VRI)) or through a translation, or through other meaningful mechanisms such as video, audio, posters, etc.
    2. Always offer meaningful access free of charge and without undue delay (timely manner).
    3. Protection of confidentiality and accuracy of interpreting should always be of highest concern, particularly if the interview concerns topics that may negatively affect eligibility for services.

Discrimination is Against the Law

The U.S. Department of Health and Human Services’ Office for Civil Rights prohibits discrimination in its programs because of race, color, national origin, age, disability and sex, including sex stereotypes and gender identity. If you believe you have been discriminated against, you have the right to file a complaint directly with the federal agency at:

U.S. Department of Health and Human Services Office for Civil Rights, Region V
233 North Michigan Avenue, Suite 240
Chicago, IL 60601
312-886-2359 (Voice) 800-368-1019 (Toll Free) (800) 537-7697 (TTY)

In Minnesota, if you believe you have been discriminated against because of race, color, national origin, religion, creed, sex, sexual orientation, public assistance status, or disability, you have the right to file a complaint with:

Minnesota Department of Human Rights
Freeman Building, 625 Robert Street North
St. Paul, MN 55155
651-539-1100 Telephone 800-657-3704 (Toll Free) 651-296-1283 (TTY)

If you believe you have been discriminated against under federal laws, state laws, or both, you may also file a complaint with the following government bodies:

MNsure Accessibility and Equal Opportunity (AEO) Office
81 7th Street East, Suite 300
St. Paul, MN 55101-2211
AEO@MNsure.org 1-855-366-7873 (Toll Free)

Minnesota Department of Human Services
Equal Opportunity and Access
P.O. Box 64997
St. Paul, MN 55164-0997
(651) 431-3040 (Voice)

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