News & Insights

Practice Managers’ Guide to Better Policies and Procedures for Deaf and Hard of Hearing Patients

July 30, 2019

By Joseph T. D. Tran, Attorney at Law

Practice Managers’ Guide to Better Policies and Procedures for Deaf and Hard of Hearing Patients

The office staff is the frontline for patient communication. A well-prepared staff is flexible enough to address both common and unexpected patient communication issues. For some, addressing the communication needs of deaf or hard of hearing patients may be new. For instance, do you know what to do if a deaf patient walks into your clinic or calls to schedule an appointment? Do you know when an in-person interpreter is necessary? Or why refusing to accept deaf patients may be discriminatory under the law?

Many of these questions and more are answered in Medical Interactive’s course Deaf and Hard of Hearing Patients: Providers’ Obligations, which LAMMICO insureds may access free of charge via their Member account by logging in at LAMMICO insureds will receive two Risk Management Credits upon completion of this one-hour learning activity. Earning two credits completes the annual requirement for the Risk Management Premium Discount Credit, a 10 percent, per-provider discount to the basic limits portion of your LAMMICO premium. 

Compliance with applicable laws can be confusing, onerous, and costly, but smart and tactful planning in creating sensible policies and procedures can help. Here are some things to consider as you are updating your policies and procedures.

“Wait, Don’t Hang Up!”

Some deaf and hard of hearing patients use video relay service (VRS), a free, subscription-based service provided by vendors, who are typically reimbursed by the Federal Communications Commissions. VRS allows a patient to use American Sign Language (ASL) to communicate with an intermediary or communication assistant (CA) via a video display. The CA translates the message to the healthcare provider. Text telephone (TTY) service achieves the same goal, but instead, the patient sends a text to the CA who then speaks to the provider. A common problem VRS and TTY users encounter is that office staff doesn’t take the calls or mistakes them as marketing or spam calls, since some of these calls start with a long pause. 

Quick Tips

  • Ask deaf or hard of hearing patients for their VRS or TTY number for any follow-up.
  • Educate staff on local VRS and TTY services and how to identify the calls. 
  • Document the VRS and TTY calls into the patient’s medical record.

“What Options Do I have?”

Video Remote Interpreting (VRI) services are cheaper to retain, easier to use, and quicker to access than in-person translators. When in-person interpreters can’t be scheduled or is cost prohibitive, VRI offers the best option for simple, routine procedures. When VRI is not an option, have contact information of interpreters in your area handy for office staff. Business associate agreements (BAAs) should be signed prior to service. If your office utilizes a last-minute interpreter, have a BAA available that he or she can sign.

Quick Tips: 

  • Educate and train office staff on how to use the VRI device expediently. List contact information for those that can help troubleshoot unexpected problems.
  • Patients who have not used VRI may be hesitant to try it. Staff can help alleviate concerns by explaining and promoting the VRI’s utility, especially if others have expressed satisfaction with the VRI.  
  • Document the use of VRI and the resulting service, whether the device provided clear, sharp video transmission, whether any unexpected delays occurred, and how the patient was informed at each step.

“Can You Hear Me Now?”

Office staff should know how to assess the communication needs of patients in person or on a phone call, but this process can become frustrating to all parties. The staff should determine the method of communication prior to the patient visit. Avoid shouting, “Can you hear me now?” to a hard of hearing person. Instead, try rephrasing, repeating, or writing down what you are communicating. If the patient calls, use the opportunity with the interpreter to ask about the patient’s communication needs, limitations, and preferences. Use the time to communicate your office’s procedures, available auxiliary aids, and any paperwork that may be completed prior to the visit.

Quick Tips: 

  • Educate and train office staff to quickly and efficiently assess a patient’s communications needs on the phone or in person. Document when training occurs and how communication assessments are made to ensure effective communication.
  • The preferences of the patient are important, but effective communication can occur through alternative means. Document when alternative means of communications is used. 
  • If a patient refuses an offered auxiliary aid or accommodation, document why and what was offered to accommodate the patient.  Nonetheless, proceeding with the best available auxiliary aid or accommodation may be necessary depending on the availability of in-person interpreters or the urgency of the patient’s appointment.

“How Do I Get Reimbursed?”

To alleviate costs associated with accommodating deaf or hard of hearing patients, health plans often provide reimbursements to providers. Restrictions do apply, so reviewing common health plans’ policies can help you maximize reimbursements when in-person interpreters are necessary. Tax incentives also exist to help alleviate some of the cost burdens. However, compliance with applicable laws is necessary regardless of whether or not providers are reimbursed. 

Quick Tips: 

  • Compile a list of health plans your office accepts that reimburse for in-person interpreters. Understand how to get reimbursed for interpreting services from different health plans. 
  • Maximize your reimbursement by knowing the special restrictions, usually related to the billing method or pool of interpreters an office may use. Research these requirements before the patient comes in for a visit, and keep an updated list for office staff to use as a quick guide.
  • Ask your tax professionals about tax credits related to use of ASL interpreters.

In addition to these quick tips, LAMMICO has Member-only resources, sample procedures, communication assessment strategies, and more that can help practices create or modify their policies and procedures. For more best practices for the medical care of the deaf or patients with other disabilities, read LAMMICO’s articles "Deaf Patients: Talking with the Hands, Hearing with the Eyes," “How Would You Communicate with Deaf and Hard-of-Hearing Patients?,” and “The Americans with Disabilities Act: Compliance Requires More Than Just Ramps.” 

For more information, please contact the LAMMICO Risk Management and Patient Safety Department at 504.841.5211.

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