Healthcare

Section 1557 Language Access Checklist for Hospitals, Health Plans and Clinics

Section 1557 requires hospitals, health plans and clinics that receive HHS funding to take reasonable steps to give people with limited English proficiency (LEP) meaningful access. Under the May 2024 rule (45 CFR part 92), that means qualified interpreters and translators at no cost to the patient, a notice in at least 15 languages, written procedures and staff training.

Key takeaways

The rule covers health programs and activities that receive HHS financial assistance.
45 CFR 92.201 requires qualified interpreters and qualified translators.
Machine translation of critical content must be reviewed by a qualified human translator.
Notices of available language help belong on your website, in your facilities and with key communications.

In this guide

July 5, 2024

Date the Section 1557 rule took effect

15 languages

Minimum for the notice of available language help

20-point

Minimum sans serif font for posted notices

Who Must Follow the Section 1557 Rule?

The rule applies to health programs and activities that receive federal financial assistance from HHS. It also covers programs HHS administers and Affordable Care Act Title I entities, such as the Marketplaces (45 CFR 92.1). Hospitals, clinics and health plans usually fall in scope through Medicaid, CHIP or HHS grants.

What Does 45 CFR 92.201 Require?

Section 92.201 requires reasonable steps to provide meaningful access to each individual with LEP, including companions. The key rules are:

Language assistance must be provided at no cost to the individual, and must be accurate, timely and protective of privacy and independent decision-making (92.201(b)).
When interpretation is required, you must offer a qualified interpreter (92.201(c)(1)).
When translation is required, you must use a qualified translator (92.201(c)(2)).
Machine translation of critical, technical or complex content must be reviewed by a qualified human translator (92.201(c)(3)).
You may not require a patient to bring or pay for their own interpreter (92.201(e)(1)).
Adult companions and minor children may interpret only in narrow emergency or documented-request situations (92.201(e)(2) and (3)).
Staff who are not qualified interpreters, translators or bilingual staff may not be used to communicate (92.201(e)(4)).
Video and audio remote interpreting must meet quality and training standards (92.201(f) and (g)).

OCR gives “substantial weight” to the nature and importance of the program and the specific communication when it evaluates compliance (92.201(d)).

What Must the Notice of Availability Say, and Where Does It Go?

Section 92.11 requires a notice stating that the covered entity provides language assistance services and auxiliary aids and services at no cost to the individual. The notice must appear in English and at least the 15 languages most commonly spoken by individuals with LEP in the relevant state or states where you operate. It must also be available in alternate formats for people with disabilities.

You must provide the notice:

Annually to participants, beneficiaries, enrollees and applicants.

Upon request.

At a conspicuous location on your website.

In clear and prominent physical locations, in no smaller than 20-point sans serif font.

With specific communications, including the notice of nondiscrimination, the notice of privacy practices, intake forms, denial notices and Explanations of Benefits, consent forms, discharge papers, billing and collections materials, complaint forms and member handbooks.

Section 92.11(d) offers two alternatives. One is an annual opt-out process. The other is to document each person’s primary language and send materials, or the notice, in that language.

What Were the Section 1557 Compliance Dates?

The rule took effect July 5, 2024. Section 92.1(b) set later dates for specific duties. All of these dates have now passed.

Requirement	Section	Compliance date
Name a Section 1557 Coordinator	92.7	Within 120 days of July 5, 2024 (November 2, 2024)
Post the notice of nondiscrimination	92.10	Within 120 days of July 5, 2024 (November 2, 2024)
Adopt written policies and procedures, including language access procedures	92.8	Within one year of July 5, 2024 (July 5, 2025)
Provide the notice of availability in 15 languages	92.11	Within one year of July 5, 2024 (July 5, 2025)
Train relevant employees	92.9	Within 30 days after adopting 92.8 policies, and no later than the dates set in 92.9 and 92.1

The language access duties in 92.201 applied from the July 5, 2024 effective date.

Preparing for a Section 1557 review?

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Are the Language Access Provisions Still in Effect in 2026?

Yes, based on the sources we reviewed as of October 5, 2026. The court actions against the 2024 rule targeted its gender identity provisions, not its language access provisions.

On July 3, 2024, a federal court in Mississippi enjoined HHS from enforcing the rule’s gender identity provisions. On October 22, 2025, the same court vacated those provisions in Tennessee v. Kennedy. HHS published a notice of that vacatur on June 2, 2026. The notice lists the vacated sections, and 92.201, 92.11, 92.8(d) and 92.9 are not on the list. The notice states: “The other provisions of the 2024 Rule remain in force.” The eCFR, current as of October 1, 2026, still contains the full text of 92.201 and 92.11.

Federal language policy has also shifted. Executive Order 14224 (March 1, 2025) designated English as the official language and revoked Executive Order 13166. The Department of Justice rescinded its Title VI LEP guidance on April 15, 2025. A July 14, 2025 Attorney General memorandum states that the order must be implemented consistent with applicable law. The Section 1557 regulation is applicable law. We found no Federal Register notice that rescinds or suspends 92.201 or 92.11. Enforcement priorities can change, so check the Federal Register and HHS OCR announcements before each annual review.

Section 1557 Language Access Checklist

Requirement	Citation	Action	Evidence to keep
Section 1557 Coordinator	92.7	Designate a coordinator if you have 15 or more employees	Designation letter, contact details
Language access procedures	92.8(d)	Write procedures for identifying LEP needs, getting interpreters and translations, and listing qualified bilingual staff	Approved policy, annual review date
Meaningful access	92.201(a)	Offer timely language help at no cost to patients and companions	Language preference fields, encounter logs
Qualified interpreters	92.201(c)(1)	Use interpreters who meet the 92.4 definition	Vendor contracts, interpreter qualifications
Qualified translators	92.201(c)(2)	Use qualified translators for written content	Translation records, translator qualifications
Machine translation review	92.201(c)(3)	Have a qualified human translator review critical machine output	Review sign-off
No family or minor interpreters	92.201(e)	Block routine use; document any emergency or patient request	Exception records
Remote interpreting quality	92.201(f), (g)	Test video and audio quality; train users	Equipment checks, training logs
Notice of availability	92.11	Post in English plus the top 15 state languages, online, on site and in required documents	Notice files, posting photos, document templates
Staff training	92.9	Train relevant staff, including billing staff and leadership	Training records kept at least 3 years

Frequently Asked Questions

Does Section 1557 apply to private clinics?

It applies to any health program or activity that receives federal financial assistance from HHS. A private clinic that accepts Medicaid or receives HHS grants is generally covered. A clinic with no HHS funding may fall outside the rule, though state law can still apply. Confirm your funding sources with counsel to determine whether your clinic is a covered entity under 45 CFR 92.4.

Can we use machine translation for patient documents?

Yes, with limits. Section 92.201(c)(3) requires a qualified human translator to review machine translation when the text is critical to a person’s rights, benefits or meaningful access. Review is also required when accuracy is essential or when the content is complex, technical or non-literal. Consent forms, discharge instructions and denial notices often meet that test.

Which 15 languages do we use for the notice?

Use the 15 languages most commonly spoken by individuals with LEP in each state where you operate (92.11(b)). The list differs by state. An entity operating in several states uses each relevant state’s list. In the 2024 rule preamble, OCR said it had provided model notice translations in the top 15 languages for each state.

Were the language access rules struck down in 2025?

No court order we reviewed vacated the language access provisions. The October 22, 2025 vacatur in *Tennessee v. Kennedy* applied to gender identity provisions. HHS’s June 2, 2026 notice states that the other provisions of the 2024 rule remain in force. Recheck the Federal Register for later changes.

How AsianText Helps

Qualified Language Services for Health Programs

AsianText supports covered entities with each part of this checklist. We write and update language access plans and procedures. We provide qualified phone, video and on-site interpreting 24/7. Our ISO 17100 certified translation team translates notices of availability, consent forms and discharge papers. We also offer human review of machine output through AI translation and post-editing. Contact AsianText to review your Section 1557 program.

This article provides general information, not legal advice. Last updated October 5, 2026.

Written by Umar Khan

Part of the AsianText team, writing about language access, translation and interpreting for government, healthcare and life sciences.

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