Title VI

No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.

 

01. Registration (5)

How do I register to receive services under the HCA contract?

If you are a new medical provider to this contract, please create a new HCA account (you must have a valid NPI number that has been pre-registered with the HCA in order to use our system). If you are a staff member of the Department of Social and Health Services, please create a new DSHS account.

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What is an NPI Number?

NPI stands for National Provider Identifier (NPI). An NPI number is a unique 10-digit identification number issued to health care providers in the United States by the Centers for Medicare and Medicaid Services (CMS). This number allows medical providers to bill for services, and allows CTS to bill the State for interpretation services provided at your location. Medical providers must have an account with a valid NPI number, and that number must be pre-registered with the HCA in order to utilize our interpretation services. If you have any questions about your NPI number, please contact the National Plan and Provider Enumeration System (NPPES) at 1-800-465-3203 or via email at customerservice@npienumerator.com, or contact HCA at 1-800-562-3022

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Can I set up multiple logins for multiple users?

Yes you can; please click “Yes you can” for instructions.

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Is CTS LanguageLink HIPAA compliant?

We are in HIPAA compliance and our portal is HIPAA compliant. At this time, we are not accepting appointments via phone unless the system is down. You have the ability to create multiple user IDs per account with separate log-in’s in order that multiple staff may access other than the person who initially set up the account (once the account is created, it is up to the provider to manage and protect the username and password per HIPAA directives). All of our employees go through HIPAA/HITECH training and must sign off on understanding HIPAA policies. All of our contract interpreters are required to sign a business associate agreement that includes HIPPA directives.

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02. Portal & Scheduling (15)

How do I place a request for an interpreter?

Requests must be placed online through our Provider Portal .

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How do I enter an address or save a location address?

You can enter an address by going to the “Administration” tab on the portal. This allows you to edit, delete, and add locations to the portal for future use. Be sure to put the addresses in the correct boxes (address 1, address 2, etc.). Google Maps will offer suggestions of valid addresses as you type to help ensure accuracy.

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What is the Subject Number or Member ID field used for?

This field is for individual appointments when you have an LEP case number (for DSHS), a DBHR approval number (for Division of Behavioral Health and Recovery), and Medicaid ID for all medical appointments. If you are placing a block-time request for CSOs, put “NA” in this field, since there are multiple LEP clients being seen.

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Will I get an interpreter confirmation?

No. Through your Client Portal, you are always able to view filled jobs, unfilled jobs, cancellations, and the name of the interpreter that has accepted your job.

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How long does an interpreter have to wait after the appointment start time, for a patient who has not arrived for their appointment?

Interpreters are expected to wait 30 minutes after the appointment start time for a patient to arrive. After 30 minutes, the provider will need to check the interpreter out by using the “Patient No-Show” option on the check-out page.

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How do I edit a job that I have already created?

On the portal, you can search for scheduled jobs by going to your “Onsite Jobs List.” Once you find your job, click the job number. Make the necessary changes and hit “Submit.”

  • When you change the date or time of a job that already has an interpreter assigned to it, if there are no conflicts with the interpreter’s schedule, the system will leave the interpreter assigned.
  • When you change the date or time of a job that already has an interpreter assigned to it, and there are conflicts with the assigned interpreter’s schedule, the system will unassign the interpreter, cancel the job, and create a new job. The interpreter will receive an email.
  • If you change the Gender Requirement of a job that already has an interpreter assigned to it, the system will unassign the interpreter, cancel the job, and create a new job. The interpreter will receive an email.
  • If you change the Language of a job with an interpreter already assigned to it, and the interpreter is qualified in that language, the system will not unassign the interpreter and will not cancel the job.
  • If you change the Language of a job with an interpreter already assigned to it, and the interpreter is not qualified in that language, the system will unassign the interpreter, cancel the job, and create a new job. The interpreter will receive an email.
  • If you modify the Job Location Phone Number, Job Location Details, or the Interpreter Notes for a job that already has an interpreter assigned to it, the system will leave the interpreter assigned and send the interpreter an email notifying him/her about the changes.
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What does Cannot Fill mean in the job status field?

When you submit a New Onsite Job request, the system will immediately search our list of contracted interpreters to verify if there are any who speak the requested language within 100 miles of the job location. If none are found, the system will immediately display a message notifying you that the job cannot be filled. When you click the “OK” button, the Onsite Jobs List will appear, showing that the job has been set to “Cannot Fill,” letting you know immediately that other arrangements will have to be made with respect to this particular patient/appointment.

PLEASE NOTE: This automated CNF message appears only when we do not have any contracted interpreters for that specific language and area; not when a potential interpreter is busy on that particular day at that particular time.

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What is the Notes screen used for on the portal?

This is a place for you to provide the interpreter with additional information, such as assignment location information, where to park, who to check in with, etc.

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What does “In Progress” mean in the Job Status field?

This means that the job is past the two-business-days window to fill the assignment and CTS is still trying to locate an interpreter. Again, once an interpreter is secured you will see the status change to “Filled” and an interpreter’s name will appear under the Interpreter field.

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How far out can I place requests?

There is no limitation on how far out you can place requests. However, if you are a medical provider, we will perform Medicaid validation again two days prior to the appointment date. If the client is no longer eligible, the interpreter will be de-assigned.

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How much notice do you need to fill assignments?

There is no required notice; however we strongly suggest as much advanced notice as possible to maximize the chance of filling the assignment.

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How do I schedule an evening appointment?

The Client Portal is not set up to create job requests that begin after 8:00 PM, but interpreters can be requested past this time. Simply call our Scheduling Department at (800) 535-7358 option 4, and our agents will be happy to schedule an after-hours appointment for you.

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For a home visit, how will I check my interpreter in and out?

For home visit assignments we have instructed interpreters to bring a voucher. When creating the job request, check “Yes” on the question that asks, “Is this an Off-Site Appointment.” This will alert the interpreter to bring a voucher and will flag our system so we know there will not be an electronic check in/out taking place.

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I have over 100 requests to place per day. How can I send multiple requests at one time?

CTS LanguageLink offers the ability to upload a file of requests into our scheduling system via our on-line portal. If you have any questions, please contact us at hcaproviders@ctslanguagelink.com

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03. Family Appointments (3)

Creating a Family Appointment in the portal

Please use the brief power point below to see how easy it is to create a Family Appointment in your portal.

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What is considered a Family Appointment?

This is an appointment where the same authorized requestor schedules two (2) or more appointments to see multiple family members.

  • Patients of these appointments must be family members
  • Time requested for a family member appointment cannot exceed ninety (90) minutes.
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I have consecutive appointments for family members at the facility and would like to have the same interpreter, since it is the same doctor back-to-back?

If the Family Appointment is 90 minutes or less it can be requested through the online portal but if the appointment is more than 90 minutes scheduling would be a manual process that requires you to complete the form below while utilizing the following instructions (This will have to be done for each sibling/consecutive job requested): Consecutive Sibling Request Form Complete the job request form(s) as you would online

  • You do not need to go to the Client Portal for this step
  • Type job information into the appropriate field
  • Asterisk (*) Indicates field is required to be filled out
  • Input your User ID # on each page
  • Print the completed form
  • Signature has to be physically signed by the requestor

Fax the completed job request form(s) to our dedicated fax line: (360)-314-3075

  • A cover sheet is not needed
  • You will not receive a confirmation
  • If you do not see the job details on your Onsite Jobs List within 24 hours contact the scheduling center by using the following:

This scheduling is offered, Monday-Friday, from 8:00 am to 5:00 pm only

  • Any requests that come in after hours will be completed the following business day, during the business hours of 8:00 am to 5:00 pm

**NOTE: Documents received without the User ID # and Signature will not be processed**

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04. Cancellations (2)

How can I cancel an appointment?

To cancel an appointment, simply go to your Onsite Jobs List on the portal, find the appropriate job and click the “Cancel” button next to the job number. Please note that if you want to cancel a job that is less than 24 hours away (excluding holidays and weekends), you must contact our schedulers at 1-800-535-7358 (select Option 4). For example, to use the Client Portal to cancel a job scheduled for 9 a.m. on Monday, you must complete the online cancellation no later than 9 a.m. the previous Friday.

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Will I get an e-mail confirmation for cancellations, cannot fills, and filled jobs?

CTS will only notify providers of jobs that cannot be filled. You will need to verify through the portal if your appointment has been filled or cancelled.

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05. About Interpreters (14)

Can an Interpreter be left alone with the Patient?

Interpreters should never be left alone with the patient, regardless of the situation.

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How to Work with your On-Site Interpreter

YOUR ROLE
When working with an on-site interpreter, there are a few things you should keep in mind to ensure your interpretation is handled successfully.

  • Always speak in first person, just as you would in normal conversation. For example, say, “Do you have a fever?” rather than “Ask her if she has a fever, please.”
  • After you speak one-two sentences or finish a thought, pause to give the interpreter enough time to interpret.
  • Be prepared to explain some things in more detail for the interpreter. Some terminology and concepts may not have an equivalent in the target language.
  • Control the conversation. The on-site interpreter is only there to interpret. You are responsible for making sure the limited English proficient (LEP) client receives the same service as an English-speaking client.
  • Ask the interpreter and the LEP client questions to ensure they understand what you want to communicate.
  • Avoid asking the interpreter for his/her opinion about the situation being interpreted.
  • Follow up by providing us with feedback about your interpretation services.

 

YOUR ON-SITE INTERPRETER’S ROLE
We expect our interpreters to meet high standards and want to know when they are meeting our expectations.To that end, your feedback is critical.

  • Your interpreter should not have a side conversation with you or the client. He or she must relay everything that is said back to you or your client. This includes any advice that the client may ask of the interpreter.
  • Your interpreter should not discuss anything unrelated to the interpretation.
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How do I place a request for an interpreter?

Requests must be placed online through our Provider Portal.

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Will I get an interpreter confirmation?

No. Through your Client Portal, you are always able to view filled jobs, unfilled jobs, cancellations, and the name of the interpreter that has accepted your job.

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Why can’t I see the interpreter name I would like to request?

Our program only lists interpreters that are available for the date and time requested.

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When am I able to request a specific Interpreter?

Requesting a specific interpreter is an optional field that should only be used when it is medically necessary to have a specific interpreter. HCA is requiring that requests for specific interpreters meet the outlined requirements below and providers must provide supporting documentation from the specialist or person providing treatment. If the exact interpreter is unavailable, the Provider may contact CTS for options. Per the contract, we will only honor specific interpreter requests under the following circumstances:

  • Active cancer treatment
  • Continuing counseling sessions
  • Applied behavior analysis therapy sessions (regardless of age)
  • Cancer treatment as requested by the provider
  • Effectiveness of treatment plan where a change in interpreter will impact the effectiveness and efficacy of the appointment
  • Pediatric Private Duty Nursing sessions in the home setting, in which the treatment plan requires frequent communication, such as when the child’s care needs are changing, where a change in interpreter will impact the health outcome or effectiveness of the interaction

A provider may still request a specific gender for appointments where it is appropriate for effectiveness of the treatment. If providers feel that none of these options apply or they need further clarification they may contact CTS at hcaproviders@ctslanguagelink.com or by phone at 800-535-7358. For further assistance or clarification, contact HCA by email at INTERPRETERSVCS@hca.wa.gov

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What if I need two interpreters for the same appointment for example ASL and Spanish?

You will first need to fill out a Consecutive-Sibling Form for each interpreter needed. Before faxing it to our schedulers you will need to note on each form that these two interpreters are for the same patient/job. Our staff will then create each appointment. You will be able to check the interpreter in and out through the portal as normal.

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Do I need to call the patient to confirm the appointment the night before? Will the interpreter call the patient the night before?

Under the terms of this contract, there is to be no un-supervised contact between Interpreters and the patient. Meaning, Interpreters are not allowed to make confirmation calls to the patient.

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How long does an interpreter have to wait after the appointment start time, for a patient who has not arrived for their appointment?

Interpreters are expected to wait 30 minutes after the appointment start time for a patient to arrive. After 30 minutes, the provider will need to check the interpreter out by using the “Patient No-Show” option on the check-out page.

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How will I know that the person in my office is a CTS LanguageLink interpreter?

While interpreters do not carry a CTS LanguageLink ID badge, when a provider or LEP client requests identification, the contracted interpreter must present picture identification or a DSHS certificate or authorization letter.

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For a home visit, how will I check my interpreter in and out?

For home visit assignments we have instructed interpreters to bring a voucher. When creating the job request, check “Yes” on the question that asks, ‘Is this an Off-Site Appointment.’ This will alert the interpreter to bring a voucher and will flag our system so we know there will not be an electronic check in/out taking place.

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How do I know the interpreter is properly immunized?

As of September 15th, 2014 CTS LanguageLink will require all medical interpreters to have submitted their proof of immunizations for the following:

  • Rubella vaccination or proof of immunity
  • Rubeola vaccination or proof of immunity
  • Mumps vaccination or proof of immunity
  • Varicella vaccination or proof of immunity
  • Diphtheria vaccination
  • Pertussis vaccination
  • Tuberculosis screening
  • Seasonal Influenza Vaccine (Due by Nov 30th of current year unless there is an active pandemic)

Failure to provide any required documents will result in the interpreter’s inability to provide interpretation. Any additional immunizations required at specific clinics will be at the provider’s discretion to ensure.

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What if I have interpreters that I do not want back at my facility? How will you handle this and what is your customer feedback process?

CTS LanguageLink is required to follow the corrective action policies set forth in the contract. For more information, see the Complaint Policy – Procedures.

The State will not ban interpreters from specific locations, nor can CTS enforce bans. If an interpreter continues to accept jobs at a facility that they are not welcome, the facility can DIRECTLY submit a letter to the interpreter informing them they are no longer welcome at their establishment. The letter must be directed to the interpreter not CTS. Once this letter has been submitted, the facility will need to provide CTS with a copy of the letter to ensure all parties have been informed.

For questions or concerns, please contact CTS LanguageLink

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How do I submit a complaint about a specific Interpreter?

Click on “Feedback On Interpreters” located under the “Customer Feedback” tab. On the left, click the “New” button. Complete the following sections of the form:

  • Your Information
  • Job Information
  • Incident Description
    • Make sure to be as detailed as possible about what happened during this Incident. Include any names of staff who can be called upon for more information regarding the Incident

You will receive an email notification that the Incident has been created and have the option to review the incident through the Incident List. When the incident has been resolved you will need to select Closed Status when searching.

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06. Feedback (2)

There are two forms under the “Customer Feedback” section in my portal. Which one do I use?

Utilize the “Customer Feedback Form” for the following:

  • CTS Agent or System related
    • Issues with your portal
    • Issues with the HCA contract
    • Issues when contacting CTS directly
  • System or CTS employee praises
    • General Interpreter praises

Utilize the “Feedback On Interpreters” form for the following:

  • Interpreter related issues
    • Not Interpreting correctly
    • Issues with professionalism
    • Issues with punctuality
  • Interpreter specific praises

Q. How do I submit a complaint about a specific Interpreter?

Click on “Feedback On Interpreters” located under the “Customer Feedback” tab. On the left, click the “New” button. Complete the following sections of the form:

  • Your Information
  • Job Information
  • Incident Description
    • Make sure to be as detailed as possible about what happened during this incident. Include any names of staff who can be called upon for more information regarding the incident

You will receive an email notification that the Incident has been created and have the option to review the incident through the Incident List. When the incident has been resolved you will need to select Closed Status when searching.

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How do I submit a complaint about a specific Interpreter?

Click on “Feedback On Interpreters” located under the “Customer Feedback” tab. On the left, click the “New” button. Complete the following sections of the form:

  • Your Information
  • Job Information
  • Incident Description
    • Make sure to be as detailed as possible about what happened during this incident. Include any names of staff who can be called upon for more information regarding the incident

You will receive an email notification that the Incident has been created and have the option to review the incident through the Incident List. When the incident has been resolved you will need to select Closed Status when searching.

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07. Service Modality (5)

What modality of interpretation should the provider choose?

The patient and the provider ultimately have the right to choose the appropriate method of communication. On-site interpreting is most appropriate for complex, sensitive medical interpreting and life-threatening situations such as:

  • Sharing bad news / worsening health conditions
  • Family conferences
  • Speech therapy / neuropsych testing
  • Conscious sedation procedures
  • Hands-on teaching
  • Delicate or complex cultural brokering
  • Specific request by the patient or provider

Video Remote and Telephonic Interpreting should be considered:

  • For situation where the method of interpretation will not compromise the care provided
  • For rare or hard to serve languages
  • When in-person interpretation is not available
  • For last minute requests
  • Any time to avoid delay in patient care.
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Can I use the contract for Sign Language Interpretation?

DSHS offices have another contract for Sign Language services; therefore they cannot request Sign Language services under this contract. Medical providers can place requests for Sign Language services, but unfortunately, our ASL interpreter resources are limited at this time. However, we are actively recruiting more interpreters.

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How do I sign up to utilize Video Remote Interpreter (VRI) through the HCA contract?

In order to use VRI you first must make sure that your system meets the necessary technical requirements. Once you have established that your system meets the technical requirements, see our installation guide and download the instructions. Once the software is downloaded, you will need to contact hcaproviders@ctslanguagelink.com to finish the VRI set up and installation.

If VRI is chosen, all of the following specific performance standards must be met:

  • real-time, full-motion video and audio over a dedicated high-speed, wide-bandwidth video connection or wireless connection that delivers high-quality video images that do not produce lags, choppy, blurry, or grainy images, or irregular pauses in communication;
  • a sharply delineated image that is large enough to display the interpreter’s face, arms, hands, and fingers, and the face, arms, hands, and fingers of the person using sign language, regardless of his or her body position;
  • a clear, audible transmission of voices; and
  • adequate staff training to ensure quick set-up and proper operation.
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When can I request over-the-phone (or telephonic) interpretation services?

Only HCA medical providers are able to create new telephonic jobs through the Client Portal. To schedule a new telephonic job, click on the “Jobs” section of the navigation bar and select “Telephonic Job.” Fill out the new job form just as you would for an onsite appointment.

The only difference is that you cannot schedule a CSO block time. Please note that you will need to have your patient with you, as this contract does not allow third-party calling. At the time of the appointment, dial 1-800-535-7358 and select option 4 (scheduling). Once the operator comes onto the line, provide them with the job number and they will connect you with the interpreter assigned to your appointment.

Be aware that for Telephonic Jobs, there is no need to check interpreters in and out, since the system will automatically log the times when an interpreter is connected.

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Can I use over-the-phone interpretation services to contact my non-English-speaking patient?

Over-the-phone interpretation services are for medical appointments only. In order for CTS to remain compliant with the HCA contract, the patient must be at your facility at the time of the call; we are not able to make a third-party call to your patient(s).

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08. Client Eligibility (4)

I keep getting ineligible clients for Medicaid eligibility. How do I know what information I need to change?

Patient Eligibility is verified in real time, therefore, if you receive an error message with detailed information as to why the patient is not eligible, please make the necessary changes and click “Submit.” If the problem continues and you require further assistance, please contact ProviderOne to verify that the patient is eligible for interpretation services and eligible for the type of care being provided.

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What service type do I select?

As a way to ensure patient eligibility for various services, healthcare providers are now required to submit information about inpatient/outpatient visits and service types when scheduling interpreter appointments. These new options are cross referenced with the patient’s provider one number and their birthdate. These Service Types have been created and defined by HCA, and more information about each service type can be found on the HCA website by following this link: HCA Service Types.

If you need more information regarding covered service types, please contact Washington Health Care Authority at 800-562-3022.

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How do I know what HCA will and will not pay for?

HCA will pay for interpreter services if:

  • The client is an eligible Medicaid client.
  • The Interpreter is authorized to provide services under the HCA contract with CTS LanguageLink.
  • The interpreter is DSHS certified or qualified.
  • The medical service is covered by the client’s Medicaid medical benefits.
  • The requester is authorized to provide services to Medicaid clients.

HCA will NOT pay for an Interpreter if:

  • The interpreter is asked for by someone other than the doctor or the doctor’s staff.
  • The interpreter is a member of the client’s family.
  • The interpreter is not contracted with or approved by HCA.
  • The medical service is not covered by the HCA medical benefits package.

HCA does not pay for Interpreter Services for:

  • Administrative Services (scheduling appointments, filling out paper work). The MCO is responsible for administrative services.
  • Inpatient hospital services
  • Nursing facility services
  • RSN services
  • Services provided by any other facility, agency, or provider that is required by federal or state law, Regulation, or rules to provide those services (e.g. public health agencies, public hospitals and local health jurisdictions);
  • Nursing facility services (covered by DSHS/Aging and Adult Services)
  • Behavioral health services covered the Regional Support Network (RSN)
  • Substance Abuse Services (covered though DSHS)

Covered Services

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Will I be notified if the patients’ eligibility changes before the appointment?

CTS will not notify the provider if the patient has become ineligible for interpretative services since the initial request. CTS will cancel the interpreter request 48 hours prior if eligibility has changed — to avoid direct bills to the provider. The provider is expected to verify the patients’ eligibility up to the day of the appointment.

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09. ABA & CSO (3)

How do I schedule ABA Therapy Assignments?

For ABA Therapy Assignments, click HERE.

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I am a CSO and would like to request a specific interpreter for my block-time request. Is this possible?

Unfortunately, CSO block-time requestors are not allowed to request specific interpreters, per the guidelines of the contract.

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What do I do when I need to schedule a CSO block time, and do not have any LEP subject information?

You can click the “Subject is Confidential” button, which does not require you to input subject information, or you can just type “NA” in the subject fields.

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10. FIMC Providers (5)

Am I an FIMC/BHSO Provider?

If a provider is serving a client from Clark/Skamania who is enrolled in fully-integrated coverage with Molina or CHPW, then they could be considered a “FIMC provider.” They would either have a contract with CHPW/Molina to serve the FIMC clients, or they would execute a single case agreement with CHPW/Molina to receive payment for services rendered to a FIMC Client.

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What is FIMC?

Fully integrated managed care is a program in Clark and Skamania counties to provide integrated Medicaid coverage for physical and behavioral health services. Medicaid clients that reside in Clark and Skamania counties may choose from two Managed Care Organizations (MCOs), Community Health Plan of Washington or Molina, each of which offers the full continuum of physical and behavioral health services. Molina and CHPW have contracts with networks of providers in SW and, in some cases, across the State, to provide physical and behavioral health treatment services to Medicaid clients.

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What if CTS is unable to fill the request?

HCA has specific guidelines for requesting. If CTS cannot not fill a request and you have to go to another resource, the specific steps are to be taken below:

  Outpatient Behavioral Health Providers

  1. Request services from CTS LanguageLink (CTS) for Medicaid clients
    • If the Client is determined not to be Medicaid eligible, providers should refer to Beacon Health Options for obtaining resources.
  2. If your request is returned because CTS is unable to find an onsite interpreter, and it is not American Sign Language (ASL), crisis or E&T:
    • You should re-submit the request via the web portal requesting an alternative modality (Telephonic or Video Remote Interpretation)
  3. If CTS is unable to fill the request;
    • Identify a resource in your area that meets the minimum standards of fluency and competency.
    • Interpreters should be certified/authorized or recognized to provide the services. This will ensure they have the minimum necessary skills to support your client’s language access needs.
    • Pay the interpreter directly
    • Submit invoice electronically or by mail to CTS LanguageLink. *Reimbursement Voucher
    • CTS will process your request and provide reimbursement once payment is received from the Health Care Authority (HCA).

 

Crisis Services, Evaluation and Treatment (E&T) Providers and American Sign Language (ASL) Services

  1. Request services from CTS LanguageLink (CTS) for Medicaid clients. Please allow CTS as much time as possible to fill the request.  This ensures you receive the most appropriate resource for your need.
  • If the Client is determined not to be Medicaid eligible, providers should refer to Beacon Health options for obtaining resources.
  1. If CTS is unable to fill the request;
    • Identify a resource in your area that meets the minimum standards of fluency and competency.
    • Interpreters should be certified/authorized or recognized to provide the services. This will ensure they have the minimum necessary skills to support your client’s language access needs.
    • Pay the interpreter directly
    • Submit invoice electronically or by mail to CTS LanguageLink. *Reimbursement Voucher
    • CTS will process your request. CTS will provide reimbursement once payment is received from the Health Care Authority (HCA).

 

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FIMC Clients

Accessing Interpreter Services for clients who reside in Clark and Skamania Counties

  • For a Medicaid client, the provider must always use the Language Link process when an interpreter is needed.
  • For a non-Medicaid individual seeking crisis services under Beacon Health Options, the individual should contact Beacon Health Options to obtain access to interpreter services to be provided during the health care visit. (Non-Medicaid means the person is not eligible for Apple Health Medicaid coverage.)
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11. Additional Information (1)

What is a Written Language Access Plan?

A written language access plan is a tool to ensure adequate and timely provision of language assistance services, including compliance with the general obligations required by Federal and state laws.

 

As described by Health and Human Services

“For instance, for over 15 years, Executive Order 13166 has required each Federal agency to create and implement a language access plan responsive to the needs of the limited English proficient population it serves. [183] Moreover, the development and implementation of a written language access plan is consistent with OCR’s longstanding enforcement processes [184] and resolution agreements regarding Title VI. [185] Although we are not requiring language access plans, we encourage entities to consider whether and how they can engage in advance planning to facilitate their ability to meet their obligations under § 92.201 to serve individuals with limited English proficiency on a timely basis”.

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