Overview
DOC did not always retain evidence of interpreter services used during initial healthcare orientations and informed consent meetings. From the total population of 4,740 commitment identification numbers, we sampled 120. Out of our sample of 120 commitment identification numbers for I/Is, 15 did not comprehend English, and DOC could not provide evidence that 3 (20%) of these 15 I/Is in our sample who did not comprehend English received interpreter services during the initial healthcare orientations and informed consent meetings. Without this evidence, we were unable to determine whether I/Is received the interpreter services to which they were entitled.
If DOC management does not follow record retention requirements, which should include the establishment of internal policies and procedures requiring the retention of all evidence that interpreter services were performed, DOC cannot ensure that its I/Is understand the healthcare information presented to them so that they can make informed healthcare decisions.
Authoritative Guidance
According to Section 630.08 of DOC’s Medical Services Policy,
In the event that an inmate is unable to read, institution staff will verbally explain the procedures to them. In the event that an inmate has difficulty understanding written or spoken English, institution staff will utilize, as appropriate, auxiliary aids and services, interpreter services, or the language line so that the inmate understands the procedures for gaining access to health care.
According to Section 488.04 of DOC’s Interpreter Services Policy,
Each Superintendent/designee shall ensure that staff assigned to the areas listed in paragraph 488.03 are trained how to access the telephonic interpreter service and document when the service is utilized on [the prison population database] when working with non-English-speaking incarcerated individuals and civil commitments.
According to Section 607.02 of DOC’s Inmate Medical Records Policy,
The medical record shall be maintained from the time of commitment to release or discharge of the inmate from the custody of the DOC. Following the release or discharge of the inmate, the DOC shall retain inmate medical records for a period of thirty years.
Reasons for Issue
DOC stated that some medical providers are bilingual and may not have documented interpreter services used because they translated for I/Is themselves. DOC stated that it needs to revisit training with healthcare vendor employees regarding the documentation of interpreter services being used.
Recommendations
- DOC management should establish record retention requirements by developing and documenting internal procedures regarding the use of qualified bilingual staff members, including employees, contractors, and vendor employees, to ensure that records are retained for the use of staff interpreter services when working with non-English-speaking I/Is.
- DOC management should monitor the record retention process it establishes by periodically reviewing all interpreter service records to ensure that employees adhere to the record retention procedure. Further, DOC should reevaluate the record retention procedure as changes to the process become necessary.
- DOC management should ensure that all employees, contractors, and vendor employees are trained in the policies and procedures for all types of interpreter services used by DOC and that they are trained in how to properly document and retain the use of these services in PPD and in I/Is’ electronic medical records.
Auditee’s Response
Although based on findings associated with a limited sample (3 out of 120 individuals), DOC acknowledges that the findings of the Office of the State Auditor signal review of DOC and vendor policies related to the documentation of use of interpretation services during healthcare contacts is warranted. Training in existing and updated policies will support staff and vendor employees in achieving compliance in this area.
Auditor’s Reply
Based on its response, DOC is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | December 19, 2025 |
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