Interpretation Services

What is the issue?

Oregon has maintained a health care interpreter registry for many years, and health care providers were not required to use it until House Bill 2359 passed during the 2021 legislative session. On July 1, 2022, use of the registry for health care interpreters became a requirement. The bill addressed quality and accessibility of interpreter services and is the first in what should be a series of improvements to the field of health care interpretation to assist “health care providers” with access to interpreter services for their patients. Additionally, the bill put into statute a requirement that the State of Oregon establish a health care interpreter certification program.

Health care providers are now required to use a qualified and certified health care interpreter (HCI) from Oregon’s central registry. The term “health care provider” is defined broadly to include licensees of state health care licensing agencies and would include physicians and physician associates.

The general requirements for health care providers are below and can also be found in the OHA administrative rules. The Oregon Medical Board developed a similar set of rules for its licensees regarding the use of interpreters.

Interpreter services should be provided to patients that may:

• have limited English proficiency;
• prefer to communicate in a language other than English; or
• communicate in signed language.

Exceptions to this state requirement will require at least one of the following:

• Provider has documented proficiency in the language;
• Provider has made good faith effort to obtain an HCI from the registry; or
• The patient declined the interpreter, offered at no cost, and instead chose a different person to provide interpretation (such as a family member).

What do you need to know?

Documentation Requirements

Health care providers are expected to maintain records for each encounter that uses an interpreter. Medical providers must submit to the Oregon Health Authority evidence of documentation if requested. For each encounter that uses an interpreter, health care providers should be documenting the following:

• full name of HCI,
• HCI central registry number, and
• language interpreted.

If a patient declines the interpreter, it should be documented clearly that they were offered an interpreter at no cost and chose a different, personal interpreter.

If a health care provider is unable to find an interpreter provider that is in the registry, they will want to document the good faith efforts taken. OHA provides a guidance document on Good Faith Effort. Health care provider offices should develop policies about interpreter services and steps taken to use the central registry.

Reimbursement

The new law does not provide any changes to reimbursement. Coordinated Care Organizations in Oregon will continue to provide interpreters at their cost and Oregon Health Plan Open Card will continue to provide a flat rate for interpreters from the registry. Other health plans are not yet required under state law to cover the costs of interpreters. Be sure to review the most current OHP rate information here.

Some practices may be eligible for the Disability Access Credit to help offset the cost of providing American Sign Language interpretation services.

The Oregon Medical Association has advocated and will continue to advocate for improved reimbursement for interpreter services, and medical offices should continue to urge all health plans they work with to begin such coverage. There are specific billing codes for interpreter services, and a medical office may bill under those codes to further document services were provided even though the costs will be unreimbursed by a plan until a plan adds such coverage to enrollee benefits.

Other Considerations

Can health care provider offices use interpreter service companies that can provide online services in a cost-effective manner?

You are still able to use online interpreter services as long as their interpreters are in the central registry. There was a one-year transition period for companies outside of Oregon to register.

Will the Oregon Health Authority permit HCIs who appear in the Office of Inspector General exclusion list for Medicare and Medicaid services to remain in the registry?

OHA does not require any background checks to limit the ability to have an HCI sign up with the registry. Health care provider offices should be mindful of this issue and plan to conduct their own checks of the exclusion lists and document those checks before engaging an HCI from the registry. Health care provider offices that work with interpreter service companies will want to ensure that those companies are providing those checks of exclusion lists.

Does documentation of interpreter services provided need to be kept in the patient record or is a report from the interpreter service provider sufficient?

The language in the rules does not specify how documentation records must be maintained beyond the specific elements that are required to be noted. However, the OMA would suggest that there be sufficient documentation available to show that a qualified interpreter was used during a specific visit and if there were any noted concerns regarding communication.

If a provider is fluent in the language of the patient, can they act as the interpreter?

The expectation is that an HCI from the registry be utilized. If a good faith effort was made or if the patient declines a translator, the health care provider may use the language preferred by the patient but will need to maintain documentation of evidence of their proficiency in that language.

Health care providers should keep track of any ongoing issues related to the registry and details regarding the cost of interpreter services. There is more work to be done to help health care providers and patients access interpreter services efficiently, and having good documentation of any issues will help lawmakers improve the program.

Where can you get more information?

The Oregon Health Authority provides several resources to support health care providers with interpretation services:

• Oregon Health Care Interpreter Program Changes Fact Sheet
• Oregon Health Care Interpreter Program FAQs
• Oregon “Good Faith Effort” Guidance Document

Legislative and Rules Links:

• House Bill 2359
• OHA Rule – OAR 950-050-0160
• OMB Rule – OAR 847-010-0140
• Oregon Revised Statute 413.550 – Health Care Interpreters

Reimbursement Resources:

• Oregon Health Plan Fee for Service Interpreter Reimbursement
• Disability Access Credit
• OHP rate information

Updated October 2025

Disclaimer: This material is for informational purposes only and is not intended to constitute legal advice. The information, examples, and suggestions presented in this material (though reliable) should not be construed as legal or other professional advice. Before applying this information in legal situations, we recommend you consult with legal counsel or other health care compliance advisors.