Eligibility Criteria Rationale

In the U.S., unfortunately, interpreting in healthcare settings is still often performed by English-speaking children of parents who have limited English proficiency and who cannot communicate directly with the healthcare providers. There is a national consensus among all stakeholder groups, language access and patient advocates that this practice is unacceptable from a moral, legal, and competency standpoint. Individuals younger than 18 years of age do not possess developmental maturity to be present during certain medical encounters and to fully understand the concepts of privacy, confidentiality, patient’s autonomy and safety within the U.S. health care framework. Additionally, language skills are not fully formed until the brain reached its full critical thinking capacity which occurs around 18-19 years of age. While, this age requirement may seem obvious for many professions, due to the lack of world language educational opportunities in the U.S., it needs to be explicitly stated for the healthcare interpreter profession.

Three main factors influenced the Commissioners’ decision about this criterion. Firstly, interpreters as language professionals must possess fully developed language-related cognitive skills and abilities that allow them to comprehend and produce oral and written speech, and high-school level of general education ensures that. Secondly, interpreting in healthcare settings requires interpreters to possess some basic numeracy and scientific knowledge. Thirdly, interpreters of many languages represent refugee populations or patient cultures (e.g., countries with military conflicts or civil unrest, or severe discrimination about certain minorities) where there are limited educational opportunities beyond high-school level. Requiring general education beyond high school will exclude interpreters of refugee communities or of indigenous languages from the opportunity to get certified based on their performance. Which, in effect, will lower the quality of interpreting in those languages and impact the quality of healthcare provided to patients speaking those languages.

This seems to be an obvious requirement since by definition an interpreter is a professional who converts a spoken-communication message from one language into another and, thus, must at a minimum speak these two languages fluently. Because the CoreCHI™ and CoreCHI™-Performance credentials are granted based on passing monolingual exams in English, it is important to have evidence that candidates speak a Language Other Than English (LOTE) at the level appropriate for interpreters. Especially, because the certification exams and the specialized training requirement are not teaching to speak a non-native language. It’s important to note that, currently, in our profession, while there exists a firm agreement that language proficiency does not equal interpreting competence, it is a prerequisite for becoming an interpreter.

In 2022, CCHI conducted a national survey specifically to gather data about the Language Proficiency in LOTE for Interpreters (https://cchicertification.org/uploads/CCHI_LPI-Survey-2022.pdf). The survey results (of 470 respondents) have informed the Commissioners in establishing the level of language proficiency sufficient for interpreters as “Advanced-Mid” on the ACTFL scale or 2+ on the ILR scale. The survey results were also the foundation for determining which documentation provided in support of this requirement is acceptable.

The work of the national task force on the subject convened by CCHI and the survey results have guided the Commissioners in classifying the languages into tiers (https://cchicertification.org/language-tiers/) and determining the authoritative vendors of language proficiency tests (https://cchicertification.org/language-proficiency-testing/). CCHI has established a national initiative for ongoing review of existing language proficiency tests.

The Commissioners recognize that 40 hours of healthcare interpreter training alone will not turn a bilingual speaker into a competent interpreter. Based on the review of the market, multiple discussions with subject matter experts (SMEs), consultations with stakeholders, the Commissioners strongly believe that this requirement provides reasonable opportunity for applicants to gain proficiency in knowledge, skills and abilities critical for healthcare interpreting at a minimally-competent level. Currently, as a decade ago, there are very few college-level medical interpreter training programs (certificate-, associate- or Bachelor-level), and none of them are for languages other than Spanish and two-three other. There are many states and rural areas where there are no interpreter training opportunities in an in-person mode at all. These states, as a rule, don’t have interpreter associations either, so, no conference or local professional meetings are available as a path to professional development. Interpreters in those locations have to rely on only online training modules to get professional knowledge. Most online training modules consist of 40 or fewer hours of medical interpreter training. Most non-academic programs in healthcare interpreting are also of 40 hours duration. Thus, requiring interpreter education beyond 40 hours from all candidates will exclude interpreters of more than 90% languages from participation in certification. Requiring beyond-40-hour interpreter education from only specific languages (e.g., Spanish) is unfairly adding a burden to a specific group.