Tell the Centers for Medicare & Medicaid Services to Provide Language Access

A message from Asian & Pacific Islander American Health Forum:

This is a critical time for health reform implementation. In just 8 months, millions of Americans will become eligible to enroll in a health plan through the insurance marketplaces. An estimated 1 out of 4 of those applicants will speak a language other than English at home. Providing translated applications will be critical to enrolling limited English proficient individuals, and to the success of health care reform.

Please sign-on to the attached letter urging the Centers for Medicare & Medicaid Services to translate the single, streamlined application into at least 15 languages. A copy of the text is also available below. To join, please complete the following form by 6pm EST on Tuesday, February 12: http://bit.ly/14C3ZUR. We can only accept national, state or local organizational sign-ons.

For more information, contact Priscilla Huang, Asian & Pacific Islander American Health Forum, (202) 466-7772 or phuang@apiahf.org or Mara Youdelman, National Health Law Program at (202) 289-7661 or youdelman@healthlaw.org

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(Download this sign-on letter)

Dear Administrator Tavenner:

The undersigned organizations urge the Centers for Medicare & Medicaid Services (CMS) to translate the single, streamlined application for insurance affordability programs into at least fifteen languages. Without translated applications, one out of four expected insurance marketplace applicants who speak a language other than English at home are at high risk of being left behind. The more than 24 million limited English proficient (LEP) individuals across the country deserve equal access to the new coverage options available under the Affordable Care Act (ACA).

The application provides the initial entry point to apply for health insurance and is a vital component of the ACA’s “no wrong door” approach to enrollment. Yet LEP individuals may suffer erroneous denials of eligibility because they do not understand what information to provide. Indeed, they may be prevented or dissuaded from accessing the insurance marketplace altogether, undermining the goal of the ACA to expand affordable insurance coverage for all Americans.

The federally facilitated exchange (FFE) must comply with both Title VI of the Civil Rights Act and Section 1557 of the ACA. To prevent discrimination against LEP individuals, the FFE must ensure access and understanding for LEP consumers. In addition to the legal requirements, federal translation of the application would benefit all entities engaged in enrollment, outreach and education. Translated applications will assist in ensuring effective communication by creating a baseline for standardizing ACA-related enrollment terminology and creating translation “glossaries” that can be used by other entities for outreach, education and training, saving costs of re-translating the same terms. Translated applications can also help train bilingual staff and interpreters who will assist LEP individuals to ensure consistency and accuracy, thus aiding effective enrollment and information dissemination.

Translating applications at the federal level is cost-effective for CMS and the states. For example, if the nineteen states operating state-based exchanges use the single, streamlined application but translate it independently, the costs multiply nineteen times.  CMS has already recognized the importance of translating its documents into multiple languages with its commitment to translating beneficiary-related Medicare forms into fifteen languages. The federal investment resulted in significant efficiencies and economies of scale, benefitting virtually all Medicare providers who must comply with Title VI.

We ask that CMS commit to translating the application into at least fifteen languages and creating corresponding translation glossaries of key ACA terms that all enrollment stakeholders can access. Federal translations would save money and resources, improve access for LEP individuals, ensure compliance with federal law, and truly implement the no wrong door philosophy at the heart of creating a single, streamlined application.

For more information, contact Priscilla Huang, Asian & Pacific Islander American Health Forum, (202) 466-7772 or phuang@apiahf.org or Mara Youdelman, National Health Law Program at (202) 289-7661 or youdelman@healthlaw.org.

Sincerely,

[Signing Organizations]