SB174, An Act Establishing the Licensure of Interpreters and Oral Transliterators for the Deaf

Joint Committee on Health Care Financing

The Massachusetts Health and Hospital Association (MHA), on behalf of our member hospitals, health systems, physician organizations, and allied health care providers, appreciates the opportunity to submit comments in strong opposition to SB174, “An Act Establishing the Licensure of Interpreters and Oral Transliterators for the Deaf.” 

The hospital community has collaborated over the years with the Department of Public Health and the Massachusetts Commission for the Deaf and Hard of Hearing (MCDHH) to develop proposals to increase the number of qualified medical interpreters within hospitals, community-based clinics, and health centers. While we support continued efforts to increase the number of qualified interpreters, SB174, as drafted, would delay access to medically necessary health care services.

The provider community strongly supports all efforts to ensure that interpreters - in particular medical interpreters - have appropriate training and experience to assist with effective communication. However, there continues to be a general shortage of available and qualified medical interpreters within the state who are able to be called upon on a 24 hours a day/7 days a week basis when needed for emergency inpatient and/or routine outpatient services. In fact, healthcare providers are already often forced to pay higher costs for interpreter time and travel to various sites for emergency services because of the lack of available medical interpreters who can provide in-person services in particular service areas. Because of this shortage, hospitals have to rely, at times, on staff, family members of patients, and video relay systems developed by companies that are located out-of-state with medically trained interpreters on staff.

SB174, as drafted, would prevent hospitals and other healthcare facilities from utilizing available resources by requiring that any qualified interpreters are limited to those licensed with the MCDHH. If available employees, family members, or interpreter service companies are not able to be utilized (because they are not deemed qualified interpreters as they are not licensed with the state), then patients will have to wait long hours while an available interpreter is found. 

SB174 would also prevent the effective and efficient use of technology (such as closed caption and other video communication systems) to ensure that providers and patients are able to communicate quickly and effectively when a patient needs emergency or outpatient level services. The current cost of using electronic systems set up through such a portal is very low. These video communication systems rely upon qualified medical interpreters (certified by nationally recognized bodies such as the Registry of Interpreters for the Deaf (RID) or National Association for the Deaf (NAD)) that are available 24 hours a day, seven days a week. It is our belief that SB174 would require each company to meet both Massachusetts and nationally recognized licensure/registration standards, which would appear to be infeasible from both an operational and financial perspective. And as a result, providers would be prevented from using these sites.

While MHA understands the intent of SB174 is to develop a centralized licensure process to ensure the quality and accuracy of oral interpretation for the deaf and hard of hearing, we urge the committee to consider the necessity of maintaining flexibility in order to prevent delays in access care for all patients.

Thank you for the opportunity to offer comments on this important matter. If you have any questions or require further information, please contact MHA's Vice President of Government Advocacy, Michael Sroczynski, at (781) 262-6055 or msroczynski@mhalink.org.