Interpreter Services

Staff must inform an applicant/recipient providing his or her own interpreter of potential problems of ineffective communication caused by using his or her own interpreter. Interpreters must be offered by the agency free of cost to the client, if the individual needs interpreter services. Refer to Interpreter Release of Information for additional information on client’s own interpreter.

Interpreter Services Requirement

The CDSS Manual of Policies and Procedures (MPP) Chapter 21 regulations require:

The provision of meaningful and effective language services to all applicants/recipients in their primary language without undue delay.
The county to offer and provide an interpreter at EACH client contact once the need for an interpreter is identified by the county or the client.
That applicants/recipients NOT be compelled or encouraged to use their own interpreters, and to explain to clients of potential problems for ineffective communication when using own interpreters.
That clients not use minors to interpret, unless under extenuating circumstances. Refer to Use of Minors as Interpreters for additional information.
That substantive, program-related conversations with the applicant/recipient shall NOT be conducted until qualified interpretive services are available.

Interpreter Services Documentation

The method(s) used to document compliance requirements (CDSS MPP Chapter 21) must be noted in the CalSAWS case Journal. This ensures that the method used to provide interpreter services meets the federal and state law and Civil Rights mandates to document the language assistance services provided must be thoroughly documented in the case Journal.

Using an interpreter who speaks a different dialect of the language may lead to misunderstandings. To mitigate this, the worker shall double-check that the client understands the interpreter before proceeding with the interview.

The state requires the following information to be documented in the case Journal for each contact with the client:

The client was offered free interpretive services.
Who provided the interpretive services (method in which interpreter services were provided) such as:
- The assigned caseworker is bilingual, or
- An outside contracted interpreter (Name) acted as the interpreter, or
- The client provided their interpreter (Name), or
- A volunteer interpreter (Name) was used, or
- Another employee (Name) acted as the interpreter.
A minor temporarily acted as an interpreter due to extenuating circumstances, with an explanation of those circumstances. Refer to Use of Minors as Interpreters for requirements and limitations.
Documentation that client(s) denied the county’s offer of interpreter service when offered and beneficiary insisted on providing their interpreter, and/or if the Social Services Agency needs to provide one for them throughout the interactive process.
That the client was informed of potential problems of using their interpreter including:
- The possibility of ineffective communication,
- Inaccurate interpretations,
- The need to disclose private information to the interpreter.

Note: If staff determines that the client’s interpreter is not competent to provide quality and accurate interpretations, and/or issues of confidentiality, privacy, or conflict of interest arise; staff shall provide competent interpreter services and allow the family member or friend to remain as a patient advocate.

County-provided interpretive services were offered when the client-provided interpreter was not available.
The client was informed of their right to accept county-provided interpretive services at any time, even when a client-provided interpreter is present.
The County provided interpretive services even when a client-provided interpreter was present.

Interpreter Release of Information

To meet the confidentiality requirements for applicants/recipients when individuals other than agency employees are used as interpreters, and to ensure compliance with CDSS MPP Chapter 21 State Compliance, an Interpreter Services Statement and Confidentiality Agreement (CR 6181) must be obtained.

The case record must be thoroughly documented in Case Comments, to indicate:

Release form was completed and signed by client and interpreter.
That client was informed of the potential problems for ineffective communication when using own interpreter, and
That free interpreter services were offered.

A copy of the CR 6181 must be Imaged into CalSAWS.

Note: The CR 6181 does not need to be completed when Voiance or other Contract staff are used. However, documentation that any interpreter services were used needs to be entered into Case Comments.

Responsibility for Scheduling

Interpreter services will be requested by the person who is actually scheduling the appointment. (i.e., The receptionist for the first intake appointment, or the worker for any other appointments).

Clients Own Interpreter Arrives

If the client arrives with his or her own interpreter, SSA should advise client that agency provides certified language interpreters. Refer to Use of Minors as Interpreters, Interpreter Release of Information and Video Remote Interpretation (VRI) for additional information when using own interpreter.

Note: Staff are to follow all other procedures as if an interpreter had been requested, such as inputting Case Comments and/or Special Indicators.

Requesting Interpreter Services

Use the following guide to request interpreter services:

Who	Action
Worker or Receptionist	Determines interpreter services are required. Completes top portion of “Interpreter/Translator Services - Detailed Service Record” (SC 1257) form. Gives SC 1257 to Supervisor for approval/denial.


Supervisor or Approving Authority	If approved, signs in the Approver’s box. Returns SC 1257 to Worker/receptionist.

Worker or Receptionist	Phones appropriate agency. Schedules appointment and advises the interpreter of the reporting location. Receptionist: Advises the interpreter to check in at the Reception Desk upon arrival. Records the interpreter’s Name and Organization Name on the appropriate lines on the SC 1257 form. Enter the appointment date and times in the Approver’s box.


Interpreter	Comes in for scheduled appointment. If intake appointment, see special procedure below. Refer to Use of Minors as Interpreters.
Worker	Completes the bottom portion of the SC 1257 at the conclusion of the interview beginning with Total Time with Client. Sets up time with the interpreter for a return appointment, if needed, and initiates another SC 1257 form. Notes the date, interpreter’s name and time of services in Case Comments. Scans the SC 1257 into the IDM System. Note: The form is available in the Intranet SSA Forms Library.

Use of Minors as Interpreters

It is Santa Clara County’s policy that the use of minors is PROHIBITED, unless used under extenuating circumstances. If a minor is providing interpreter services, this must be thoroughly documented in Case Comments and the reason a minor was used.

Examples of Extenuating Circumstances warranting the temporary use of a minor as an interpreter include, but are not limited to:

The worker telephones or visits the applicant/recipient’s home for initial contact and finds a non-English or limited-English speaking client. Under these circumstances, the minor can be used as an interpreter ONLY to determine the language of the client and to schedule a date and time to call/return with a county provided interpreter.
A non-English or limited-English speaking applicant/recipient comes to the office with a minor child who speaks English and the county does not immediately have access to a county provided interpreter in the applicant/recipient’s primary language. Under these circumstances, the minor can be used as an interpreter ONLY to schedule a date and time for the client to return to the office when a county provided interpreter will be available, and case comment entered to reflect the extent of the use of the minor to provide interpreter services.

Example Example Visitor speaks Gujarati. His 12 year old daughter accompanies him to the office. There is no immediate interpreter available on site. Staff calls the Voiance Interpreter Services to request a Gujarati interpreter who is available the following day. Case Comment Documentation: “Client’s daughter informed her father that a Voiance interpreter is available for the scheduled Intake appointment.”

When a county employee encounters a health/safety issue, such as a car accident or crime scene, where immediate communication is imperative, a minor may be used temporarily UNTIL a qualified interpreter arrives at the scene or communicates with the applicant/recipient via phone, etc.

Special Intake Appointment Instructions

The instructions for requesting Interpreter Services are outlined below when an assigned interpreter shows up for a special intake appointment:

Who	Step	Action
Interpreter	1.	Explains to the Receptionist they are there to assist in completing the “Identification and Intake Record” (SCD 41) process.
Receptionist	1.	Gives the interpreter and applicant the SCD 41 and appropriate application(s) to complete.
	2.	Marks off the appointment on the blotter.
	3.	Calls the worker for the intake appointment.
Worker	1.	Follows instructions for completion of SC 1257: Refer to Requesting Interpreter Services for instructions. If a second appointment is needed, a second SC 1257 is logged in and attached to the SCD 41.