Jon Peacock, Wisconsin Council on Children and Families

The Children’s Health Insurance Program Reauthorization Act (CHIPRA) approved by Congress early this year gives states financial assistance and policy options that help states maintain and improve coverage of kids.  One source of financial assistance that has gotten less attention is an enhanced federal match rate for interpretation and translation services.

The new rate, which is 75% for children in Medicaid (and potentially slightly higher for kids covered by CHIP), applies to translation and interpretation services needed to assist children in applying for coverage or at renewal, or to improve communication when care is being provided. Like some of the other parts of CHIPRA, this is an area where there is still some uncertainty, but it’s important to start thinking about how states can take advantage of the increased federal funding for these services.

Initially, it was unclear to me whether or to what extent the higher federal matching rate would help states like mine (WI) that primarily use managed care, since the managed care entities (MCEs) generally get one flat rate for each enrollee, rather than reimbursement for each service. However, after preliminary conversations with WI DHS staff and other experts, and after recent guidance from the Centers for Medicare and Medicaid Services (CMS), it appears that there are at least 4 sorts of ways that the higher matching rate for translation can be of assistance in all states:

• to translate outreach documents;
• to help support bilingual workers who assist with applications or renewals;
• to improve communications with non-English speakers when kids are receiving fee-for-service care, such as emergency Medicaid services; and
• to provide increased federal reimbursement (to the state) for spending attributable to interpretation services provided by MCEs when caring for children.

In recent weeks CMS has issued several documents that provide guidance to states on how CHIPRA will be interpreted and how states can take advantage of it. One of those, issued on Sept. 3, is a Q & A format document that addresses – among other issues – the matter of how the enhanced federal match for interpretation services will apply to MCEs. At question # 9, CMS says:

“States will be permitted to claim the enhanced match for that portion of the capitation rates paid to MCEs that can be documented as attributable to the cost of translation and interpretation services under the contract. CMS will work with States to develop an allowable methodology to collect the information necessary to claim this higher matching rate for the eligible portion of their managed care payment rates.”

As we wait for additional CMS guidance on some aspects of the new federal law, it isn’t too soon for states, advocates, and providers to begin planning how they can utilize the enhanced federal matching rate to more effectively serve children in families that are not proficient in English.

The views expressed by guest bloggers do not necessarily reflect the views of the Center for Children and Families.