Overview
During the audit period, RHAP participants did not always receive interpreter services from DPH or RHAP providers during their health assessments. Specifically, we inspected the health assessment forms of 73 RHAP participants to determine whether an interpreter was present during the health assessment. We found that 7 out of 73 RHAP participants in our sample did not have an interpreter present during their health assessments when they may have needed one. An interpreter is required to be present during a health assessment if a refugee requires assistance with understanding medical professionals who may not speak a refugee’s preferred language.
When RHAP participants do not receive health assessments in a language that they can understand, there is a higher-than-acceptable risk that their healthcare needs may not be communicated and/or addressed.
Authoritative Guidance
Section 207 of Chapter 6 of the General Laws states, “[ORI] shall have the following powers . . . (f) to increase the availability and utilization of qualified interpreter services.”
Reasons for the Issue
ORI informed us that the seven RHAP participants we identified may not have needed interpretation services during their health assessments. However, we could not corroborate that information because the health assessment forms did not have a field for RHAP participants to document their preferred languages.
Recommendations
- ORI should ensure that RHAP participants receive interpretation services when required.
- ORI should ensure that health assessment forms have a field for RHAP participants to document their preferred languages.
Auditee’s Response
Language access is a cornerstone of effective Refugee Health Assessment Program (RHAP) services. Sites must have robust systems in place to ensure the identification and utilization of trained medical interpreters, including those provided through telephone, web-based, or other emerging technologies. Our commitment to language access is unwavering, and we are dedicated to continuously improving our processes to ensure that all participants receive the necessary support.
After carefully reviewing the seven RHAP forms that were found to lack interpreter reporting data, and upon further electronic medical record (EMR) requests from RHAP sites, we have confirmed that all seven individuals did, in fact, receive appropriate access to interpreter services.
Specifically, three of the individuals were children whose parents did not require an interpreter, as indicated on the parents’ RHAP form. Additionally, one adult participant did not need interpreter services. Two participants were screened on the same day along with their respective family members, and based on the family members’ RHAP forms, it was extrapolated that interpretation services were provided. It is worth noting that DPH encourages RHAP providers to conduct RHAP screening services as a family unit whenever possible, in order to minimize access barriers and burdens for the participants.
Furthermore, the seventh participant had two RHAP forms, one from an uncontracted site, Greater New Bedford Community Health Center (GNBCHC), and the other from a contracted screening site, Boston Medical Center (BMC). Notably, the BMC RHAP form, which was not included in the audit review, indicated that the patient did not require an interpreter.
We understand the importance of offering interpretation services in refugees’ preferred languages. Resettlement agencies must complete RHAP referral forms with a specific field for the patient’s preferred language. We recognize that the unprecedented increased volume for resettlement and RHAP has posed challenges, resulting in oversights in completing the interpreter field on the RHAP form.
We are committed to ensuring that all services are delivered by physicians or midlevel clinicians and their appropriately supervised staff, with trained medical interpreters, in a manner that is responsive to refugees’ language, experiences, and culture, following the RHAP procurement document.
Auditor’s Reply
In its response, ORI states that the seven RHAP participants that we identified in our finding as not having interpreter services documented on their health assessment forms did not require interpreters. ORI states that it was able to confirm this by reviewing the electronic medical records of these seven participants, which were obtained from each RHAP participant’s provider, and by reviewing each participant’s RHAP referral form, which has a field to document whether each RHAP participant requires an interpreter.
During the course of our audit work, on October 6, 2023, we requested copies of the RHAP referral forms for the 73 RHAP participants in our sample. We requested this information again on December 1, 2023. On December 22, 2023, ORI provided us with copies of RHAP referral forms for 21 out of the 73 RHAP participants in our sample. We then further requested the remaining 52 RHAP referral forms from ORI in an email on January 24, 2024. On January 30, 2024, ORI replied to our email, stating,
Referrals forms are used to create and or update . . . events for RHAP clients. The program does not retain these forms after that point. The 21 forms were the only forms available and corresponds to the list provided by the auditors.
We further note that we only received RHAP referral forms for two of the seven RHAP participants identified in our finding as not having interpreter services documented on their health assessment form. Contradicting ORI’s response, we found that one of the RHAP participants represented by those two referral forms indicated on their form that they needed interpreter services that were not provided to them.
As such, because ORI does not retain RHAP referral forms for its RHAP participants, we maintain that the need for interpreter services should also be documented on each RHAP participant’s health assessment form (a different document) to ensure that RHAP participants receive their health assessments in their preferred language and to create an audit trail that allows for improved oversight and transparency to the public on these matters.
| Date published: | November 14, 2024 |
|---|