Language Access Programs

You already have the policy. What you need is a way to run it every week, in every department, and show your work afterward.

Almost nobody calls us to ask whether they need a language access policy. They already have one. 

What they call about is harder. Can the policy run in every department with staff who weren’t in the room when it was written? And when someone asks what the agency did, is there a record?

We are The Translation Company, and we have operated since 2005. We build language access programs for four kinds of institutions:

• Public agencies
• Health plans
• Hospitals and healthcare providers 
• School districts 

Most of the time we are working inside a plan somebody else wrote. When the policy or program still needs development, then the work starts earlier than that. 

Before anything else, who this is not for.

If the objective is to collect ten bids and buy the lowest per-word price, we will not be competitive, and we will usually decline the bid. We say it now rather than after a contract is signed, and we learned to say it the expensive way. In our first years we accepted work from organizations whose expectations we could not meet. It went badly for both sides. The policy came out of that.

Since 2005: Operating continuously ·  200+ Languages in 40+ countries ·  4 Core Settings: agencies, plans, providers, schools  ·  Program first: Policy translated into operations

ON THIS PAGE

• Two Separate Duties (Most Programs Only Run One)
• The Questions the Policy Leaves Open
• Start with the Policy You Already Have
• When the Program Still Needs Assessment
• Four Settings, Four Different Problems
• What Gets Translated in Advance and What Waits for a Request
• Who May and May Not Interpret
• Qualified Language Assistance and The Role of Interpreting
• Machine Translation and the Review the Regulation Requires
• When the Translation is Right, and the Document Still Fails
• Who Pays For It and What You Can Claim Back
• What Working with The Translation Company Looks Like
• Talk With Us About Your Language Access Program

Two Separate Duties (Most Programs Only Run One)

Procurement documents name two obligations. They come from different statutes, cover different people, and inside most institutions they are owned by different coordinators.

• Meaningful access is the language duty. It comes from Title VI of the Civil Rights Act, and for health programs and activities receiving federal funds, from Section 1557 of the Affordable Care Act. It covers people who do not read, speak or write English well enough to use a program without help. The remedy is translation and interpretation by qualified people.
• Effective communication is the disability duty. It comes from the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. It covers people who are deaf or hard of hearing, blind or low vision, or who have speech or cognitive disabilities. The remedy is auxiliary aids and services: ASL interpreters, CART, captioning, Braille, large print, audio, accessible electronic documents.

An organization can be fully compliant on one duty and exposed on the other, in the same document, on the same day. A county that translates a notice into six languages and posts all six as untagged PDFs has met meaningful access and failed effective communication.

The two duties also tend to have different owners. The language access coordinator and the ADA coordinator sit in different departments, hold different budgets and buy from different vendors.

The Questions the Policy Leaves Open

A policy can say that qualified language assistance will be provided. It does not say how a staff member know what language a person needs, and who approves terminology? Or what happens to a PDF, form or portal page after the English version changes.

A program that works has routes instead. 

• A standing route for the communications that come round every year. 
• A request route for the ones that do not. 
• An escalation route for the urgent and the unusual. 
• And a record of what was asked for and what was sent.

For The Translation Company, language access sits above any single service. Translation, interpreting, accessible documents and alternate formats are all capabilities the program draws on. What the program decides is which one a given communication needs.

Start with the Policy You Already Have

Most of our clients arrive with something already decided: a board directive, a contract requirement, a plan document, or a practice everyone already follows. We are not going to hand you our theory of language access when you have already adopted one.

So the first job is finding the possible friction point. Sometimes, it is a recurring set of notices that needs translating into threshold languages that are already established. It can also be several departments under one terminology and file-management process. Sometimes, it is an intake route that lets urgent  requests bypass review.

This work is rarely greenfield. A health plan has years of member-material history. A county knows its principal languages but not what to do when a department’s needs shift mid-year. A school district has parent communication down and IEP meetings inconsistent. The plan usually exists but making it easier to run is the work.

When the Program Still Needs Assessment

Some organizations do need help earlier in the process. There is a requirement, and there is nothing built underneath it yet. How much of the following we do depends on what you already own and what you would rather hand over.

• Assess language from records you already hold: enrollment, member, patient, student or service-area data.
• Separate the languages a statute names from the ones that simply keep arriving.
• Inventory the vital documents. Not every English-language asset belongs in the same translation queue, and deciding that early is what keeps the budget honest.
• Map where oral language assistance is actually needed, including call centers, front desks, IEP meetings.
• Name who can request work, who approves terminology, and what happens when the English source changes. 
• Build escalation routes for uncommon languages, urgent notices, and anything carrying legal or clinical risk.
• Set reporting categories so the program can be managed from numbers instead of anecdote.

Most plans written before 2025 were built on the four-factor analysis: 

• How many people with limited English proficiency the program serves
• How often they contact it
• How important the communication is to them
• What resources the institution has

It is still the right way to think about priorities. It is no longer a federal checklist that governs on its own, for the reasons set out above. Which obligation actually applies now depends on the program, the funding source and the jurisdiction and that is a question worth settling before anyone writes a scope.

Four Settings, Four Different Problems

Language access is not one market with four logos placed on it. The buyer, cadence, documents and legal triggers change by setting. We run the same program discipline across all four, but nobody should be sold the same program four times.

State, county and local government

Public agencies often have the broadest mix of communications: 

• benefits information
• public notices
• forms
• emergency material
• election content
• public meetings
• websites
• community outreach
• housing
• social-service communications

The practical problem is usually decentralization. One department may have a mature workflow while another sends urgent files through email with no shared terminology or history.

Federal language-access policy is also in transition. In March 2025, Executive Order 13166 was revoked, and the U.S. Department of Justice subsequently rescinded longstanding LEP guidance issued under it. DOJ currently states that replacement guidance is under review. The same DOJ notice also says the executive order did not itself require agencies to change the services they provide. For public buyers, the sensible response is not to assume language access vanished; it is to identify the actual requirement that applies — state statute, program rule, election law, local policy, grant or contract term, accessibility duty, or a still-operative sector-specific regulation and build the program around that requirement.

That is particularly important in states and localities that impose their own language-access duties. California, for example, continues to generate recurring translation obligations across health, public meetings and other public programs. We keep the legal trigger with the program owner and focus our role on making the required communication producible, reviewable and repeatable.

Health plans

Health plans have a different problem. For a health plan, language access is not a project. It arrives with the annual production calendar, and it never stops arriving.

Rule	Threshold
DHCS (Medi-Cal managed care)	3,000 beneficiaries or 5% of the eligible population in the service area, whichever is lower; plus 1,000 in a single ZIP or 1,500 across contiguous ZIPs
CMS (Medicare Advantage, Part D)	5% of a plan benefit package service area
HUD (safe harbor)	5% or 1,000 persons, whichever is less
VRA §203 (elections)	10,000 voting-age citizens or 5%

This is also where language, accessibility and format requirements start to converge. A translated member notice that cannot be used with assistive technology, or that cannot be produced in the member’s required alternate format, has not been delivered. Our health-plan work therefore connects naturally to member communications, document accessibility and alternate-format production rather than treating each as an unrelated purchase.

Hospitals and healthcare providers

Healthcare providers operate closer to the point where language failure can immediately affect consent, treatment, discharge, benefits or a patient’s ability to act on instructions. The current Section 1557 rule at 45 CFR Section 92.201 requires covered entities to take reasonable steps to provide meaningful access, and when translation or interpretation is required, it calls for qualified translators and interpreters. It also restricts reliance on unqualified adults, minor children and staff who are not qualified for the language role.

The same regulation is unusually direct about machine translation. When the underlying text is critical to rights, benefits or meaningful access, when accuracy is essential, or when the source material is complex, non-literal or technical, machine-translated output must be reviewed by a qualified human translator. That turns what used to be a vendor quality preference into an operating requirement for covered work.

A provider program therefore needs more than a phone number for an interpreter vendor. It needs written workflows for vital documents, clinical and administrative translation, points of care, urgent requests, qualified human review, privacy, documentation and staff escalation. Interpreting is available through TTC when required, typically through vetted partners and subcontractors; our larger role is helping written and spoken language assistance fit into the same institutional process.

School districts

School districts operate on a recurring calendar with unusually varied audiences: 

• Parents
• Guardians
• Students
• Teachers
• Special-education teams
• Administrators
• Community members

Language needs show up in enrollment, English-learner notifications, family engagement, discipline, transportation, safety, special education, meetings, district policies and day-to-day school communications.

The rules are not all the same. 

ESEA Section 1112(e) contains parent-notification requirements for English learners and requires specified notices to be understandable and, to the extent practicable, in a language parents can understand. 

IDEA separately requires public agencies to take whatever action is necessary to ensure a parent understands IEP Team proceedings, including arranging for an interpreter when the parent’s native language is not English or the parent is deaf. State requirements can add another layer.

For a district, the program challenge is consistency across schools. A central office can approve terminology and templates, but dozens of campuses still need an easy way to request translations, reach interpretation, identify language needs and know which materials already exist. A campus should be able to request a translation without waiting on a committee, and without commissioning something the district already owns in that language.

What Gets Translated in Advance and What Waits for a Request

Language-access programs gets expensive at two extremes: 

1. Translate everything in advance and you are paying to keep documents current in languages nobody asked for. 
2. Translate nothing until it is requested and you are late every time something matters. 

Neither is a strategy, and most programs need three or four routes rather than one.

• Pre-produced – threshold languages, and the vital communications that come round every cycle. 
• On-request translation – real need but too infrequent to hold in inventory. 
• Rapid-response workflows – urgent notices, and emergency where late delivery is the same as no delivery.
• Templates and translation memory – for documents that change in part rather than in whole. The more you translate with us, the larger that memory gets, and it is yours to take with you whenever you want.
• Escalated review – anything involving rights, benefits, or clinical decisions.

A threshold tells you when a language must be supported. It does not tell you which documents are vital, how fast a notice has to move, or what to do about the languages that fall below the line and keep arriving anyway. Nothing in the regulation answers those, and they are most of the operating cost.

We keep a page for each of the languages that show up most often in threshold work: who speaks it, where they are, and what the law tends to require. Start there if you are deciding whether a language belongs in your standing set.

Somali  ·  Khmer  ·  Punjabi  ·  Burmese  ·  Amharic  ·   Haitian Creole  ·  See all languages

Who May and May Not Interpret

Every institution has the same free option available to it. A bilingual staff member helps out. A patient’s daughter translates. The front desk asks whoever is nearby.

That option is not lawful for covered work, and the rules say so in specific terms.

Section 1557, at 45 CFR Section 92.201, requires covered entities to provide language assistance through qualified interpreters and qualified translators. It restricts reliance on unqualified adults, on staff who happen to be bilingual but are not qualified for the language role, and on minor children except in an emergency where no qualified interpreter is immediately available.

The ADA and Section 504 place the duty to provide effective communication on the covered entity. The obligation does not transfer to the person who needs the accommodation, and it is not discharged by asking them to bring someone.

Bilingual is not qualified. A staff member fluent in Spanish at home has not been assessed for the language of benefits determinations, appeals, discharge instructions or IEP procedure, and has not been trained on impartiality or on the limits of their own role. Nothing about their fluency is in question. Their qualification for that specific communication has not been established, and the regulation asks about qualification.

This is where most of the exposure sits. The unlawful workaround is also the convenient one, and it happens at the counter, not in the policy. A program that does not make the qualified route faster than the improvised route will keep losing to the improvised route.

Qualified Language Assistance and The Role of Interpreting

Live interactions with people need a spoken-language route, and it is not the same route for every encounter. A call-center interaction, an IEP meeting, a clinical consent discussion and a public meeting differ on continuity, specialization, scheduling and whether the interpreter needs to be seen.

The qualification question matters more than the modality. Current healthcare rules require qualified interpreters when interpretation is required. ADA effective-communication rules likewise place responsibility on the covered entity rather than on the individual to bring a family member or child to interpret, subject only to narrow exceptions. A program should make the qualified route easier for staff to use than the improvised route.

For spoken-language interpreting, ASL, CART and captioning, see our Interpreting, ASL, CART & Captioning services.

Machine Translation and the Review the Regulation Requires

Machine translation earns its place on high-volume, repetitive material. The mistake is to treat the tool as the policy.

For covered work that distinction is not ours to make. 45 CFR Section 92.201(c)(3) requires that machine-translated output be reviewed by a qualified human translator whenever the source is critical to rights, benefits or meaningful access, whenever accuracy is essential, or whenever the material is complex, non-literal or technical.

So the workflow follows the communication, not the other way round. 

Human translation from the start for anything that determines an outcome. 

Machine translation with professional post-editing where the material supports it. A lighter route for internal and low-risk content, if your own policy allows it. Where the regulation requires qualified human review, that is not a setting we adjust.

Our AI policy is also a data-handling policy. We use professional-grade tools only, under terms that forbid the vendor from training on client data or retaining it for their own use. We will put zero-retention terms in writing. 

For anyone handling health, student or legal information, this matters. It is not the one most vendors publish.

When the Translation is Right and the Document Still Fails

Accurate translation is not the same as a usable document.  

• A screen reader cannot read an untagged PDF in any language
• A translated form can still lose its reading order. 
• A member may need large print, Braille, audio or accessible electronic text. 

These are separate production disciplines internally. To the person receiving the letter they are one thing, which is whether the letter can be used.

It’s important to decide language, accessibility and format before the English source is locked. The alternative is remediating twenty finished files one at a time, and paying the same  problem twenty times. Tagging the source once and validating twenty times is cheaper, and it is the only version that holds up when the English changes.

We do document-accessibility work in-house, led by an accredited practitioner, and we connect language production with Section 508 and document accessibility workflows where the project requires it. Alternate formats run through the same program, so nobody has to reassemble one communication out of three vendors’ work.

Who Pays For It and What You Can Claim Back

The per-word rate is the small part. What usually decides whether a program is affordable is who owns the budget, how much of it comes back, and whether the vendor can get through onboarding without costing you more time than they save you.

Medicaid offers a good example. States can claim translation and interpreting as an administrative cost at the standard 50 percent federal match. Under CHIPRA, that rate goes to 75 percent for work tied to enrolling children and their families, keeping them enrolled, and helping them use the services they are entitled to. CHIP runs its own enhanced formula.

Onboarding is where small vendors usually slow large buyers down, so we have made ours boring in the best way. We are registered in SAM.gov and hold WBENC and WOSB status. Our diversity credentials are certified, not self-declared. 

Before a single word gets translated, an institutional buyer may need vendor records, insurance certificates, a security review, contract terms and a purchase order. We meet your procurement reality rather than asking you to meet ours.

We work with: 

• The County of Santa Clara
• Harris County
• The City of San José
• The City of Celina
• Newark Public Schools
• The Middleton-Cross Plains Area School District

What they have in common is that all six run inside public procurement, recurring workflows and organizations where the service must fit an existing operating structure.

For buyers preparing an RFP or evaluating vendors, our Translation RFP Toolkit provides a separate framework for requirements, scoring and supplier evaluation.

What Working with The Translation Company Looks Like

The first meeting is a working call, not a pitch. We want to know who owns the program, where language requests come into the organization, and which communications you cannot afford to get wrong. Whatever your current vendors do well, we would rather not break.

After that the scope can go either way. Sometimes we are the translation provider inside a program that already runs well. Sometimes we consolidate four departments’ workflows and terminology into one. Sometimes the work starts earlier, with an assessment or a vital-document inventory. Accessibility and alternate formats can come along with it or stay where they are.

We also believe continuity matters. You will work with the people who own the firm, not a rotating cast of junior account managers. Eleven people work continuously with us, supported by roughly 30 linguists on assignment and contractor basis. The average tenure with us is over a decade, and the reason is not complicated: we pay them fairly and we pay them on time.

That stability becomes client-side continuity: terminology, institutional knowledge and working habits do not need to be relearned every few months.

Talk With Us About Your Language Access Program

Whether you have a policy that needs running properly or a requirement with nothing built under it yet, the next step is the same and it is smaller than a procurement.