Language access plan template for NEMT companies: interpreters, translated notices, and staff steps

Who needs a written plan

Any NEMT company paid with Medicaid or other HHS money should keep one. Part 92 covers every health program that receives HHS money directly or indirectly (45 CFR 92.2), and Medicaid money reaches a transportation company through the state and often a broker. The Section 1557 rule requires every covered entity to have written language access procedures, whatever its size (45 CFR 92.8(d)), and it names five things they must contain: the Section 1557 coordinator’s contact details where one is required, how staff identify a person with limited English, how staff reach qualified interpreters and translators, the names of qualified bilingual staff, and a list of translated materials with their languages and issue dates. The rules behind those duties, including what changed in 2025 and 2026, are in our guide to serving riders who speak limited English.

That is a change for small fleets. HHS’s 2003 guidance on limited English proficiency (68 FR 47311) said recipients serving very few people with limited English, or with very limited resources, might choose not to write a plan. The 2024 Section 1557 rule made written procedures mandatory. The Justice Department withdrew its own matching guidance in 2025, but the HHS rule is a regulation and still applies.

Companies that receive FTA money as transit subrecipients have a second set of requirements. FTA Circular 4702.1B requires a language assistance plan that reports the four-factor analysis, describes help by language, explains how riders learn help is available, says how the plan is monitored and updated, and covers staff training. The template below includes all five, so one plan serves both. Our guide to Title VI plans for transportation providers covers the rest of that program.

The template

[Company name] language access plan

Effective date: [date] | Plan owner: [name, title] | Last reviewed: [date]

1. Contacts

2. Four-factor analysis

Complete this before choosing services, and redo it at each yearly review.

3. Languages we serve

4. Finding out a rider’s language

• At booking, the call-taker asks: “Which language do you prefer to speak? And to read?” The answers go on the rider profile and the trip.
• When a caller has trouble in English, the call-taker brings in an interpreter rather than continuing in English.
• Every vehicle carries a language identification card. A driver who cannot understand a rider shows the card and calls dispatch.
• A rider may decline language help. Staff note it on the profile and offer again on the next call.

The driver’s side of this, step by step, is in the language access guide.

5. Getting an interpreter

Staff never ask riders to bring or pay for their own interpreter. A rider’s adult companion interprets only as a stopgap in an emergency, or when the rider asks for it in private with a qualified interpreter present, the companion agrees, and the request is written down. A minor child interprets only as an emergency stopgap (45 CFR 92.201(e)). Deaf and hard of hearing riders follow our effective communication procedure, covered in serving Deaf passengers.

6. Qualified bilingual staff

Only employees listed here may speak with riders in another language without an interpreter.

7. Translated materials

Any document translated by software is reviewed by a qualified human translator before use when it affects a rider’s rights or access, or when accuracy matters.

8. Telling riders that help is free

The notice of free language help is in English and in the 15 languages most spoken by people with limited English in [state] (45 CFR 92.11). Check each place it appears:

• Our website, where riders will see it
• Inside each vehicle, in type at least 20-point sans serif
• The office counter or waiting area, if riders visit
• Complaint forms
• Rider guides or handbooks
• Bills and payment notices for private-pay riders
• Our notice of privacy practices, if we have one
• Sent to each rider once a year, or replaced by communicating with the rider in their recorded language

9. Training

Everyone who talks with riders, plus leadership and billing staff, completes training on this plan. Existing staff train within 30 days of this plan taking effect and within a reasonable time after any material change; new hires train within [__] days of starting. Records are kept at least three years (45 CFR 92.9).

10. Monitoring and yearly review

At least once a year, and after any complaint about language help, the plan owner:

1. Updates sections 2 and 3 with the last 12 months of trip and interpreter data.
2. Compares interpreter vendor invoices by language with the languages recorded at booking. A language that shows up on invoices but not on profiles means intake is missing it.
3. Reviews complaints and broker reports that mention language.
4. Checks that every translated document in section 7 is still current.
5. Signs and dates the plan below.

Reviewed by: __________ Date: __________

Working out which documents to translate

HHS’s 2003 guidance gives a safe harbor for written translation. If a language group reaches the lower of two marks, 1,000 people or 5 percent of the population you serve or are likely to encounter, translating your vital documents into that language is treated as strong evidence that you met the written translation duty. If a group reaches 5 percent but has fewer than 50 people, you can give that group a written notice in its language that it may have the vital documents interpreted orally, free of cost, instead of translating them. FTA uses the same thresholds.

Here is how that plays out for three example fleets, with made-up numbers:

• Fleet A carries 2,400 riders a year, so 5 percent is 120. Its 260 Spanish speakers with limited English reach the mark, so it translates vital documents into Spanish. Its 75 Vietnamese speakers do not, so it offers oral interpretation as needed.
• Fleet B carries 600 riders, so 5 percent is 30. Its 42 Haitian Creole speakers reach 5 percent but number fewer than 50, so it gives them a written notice in Haitian Creole that free oral interpretation is available.
• Fleet C carries 30,000 riders, so 5 percent is 1,500. Its 1,100 Russian speakers are under 5 percent but over 1,000, and the lower mark counts, so it translates vital documents into Russian.

The safe harbor covers written translation only, and it comes from guidance, not from a regulation, so a company below every mark still answers to the “reasonable steps” standard in 45 CFR 92.201(a). Riders in every language still get a qualified interpreter when they need one, and the Section 1557 notice of free language help still goes out in your state’s top 15 languages, whatever your counts show. HHS’s examples of vital documents include consent and complaint forms, notices of rights or of denied or reduced services, notices advertising free language help, and applications for a program. The NEMT documents that fit those categories are listed in the language access guide.

Where the numbers come from

Your own records come first. HHS’s guidance tells recipients to start from their past contacts with people with limited English, and to record a person’s language wherever records of past contacts are kept, because that record feeds the next analysis. A language field on the rider profile form and the trip makes section 3 a count instead of a guess.

Outside data fills the gaps, especially for groups that ride less because of the language barrier itself:

• Census table B16001. The American Community Survey reports, by county, how many people age 5 and over speak each language at home and how many of them speak English less than “very well.” Use that second number. HHS’s guidance warns that many speakers of a common language are fluent in English, so total speakers overstate the need.
• The state’s prevalent languages. Each state identifies the prevalent non-English languages among Medicaid enrollees, and managed care plans, including NEMT brokers paid as plans, must offer key written materials in them (42 CFR 438.10(d)). Ask your broker for the list, and compare it with your own.

Census figures describe a whole county, while your eligible riders are a smaller group, so treat them as a cross-check rather than your denominator.

Pulling the year’s numbers from HealthRide

Sections 2 and 3 need a count of the riders you served, and the trip log in HealthRide’s reports exports completed rides as a CSV or PDF to start from. When a driver at the curb needs an interpreter, team chat puts the driver in touch with dispatch from the same app they use for trips.