The California Division of Workers’ Compensation (DWC) collected stakeholder comments on proposed MPN rules in their Rulemaking Forum, a public comment board which captures pre-rulemaking discussion from the public and is a precursor to formal rule development process.
Up through the deadline of March 5, 2025, stakeholders offered nearly 100 pages of commentary, much of it centered on interpreter certification requirements. Healthesystems performed an in-depth review of the proposal and the comments submitted by stakeholders.
Numerous commenters voiced concerns regarding the removal of language pertaining to certified interpreters, particularly questioning its potential impact on interpreter qualifications and whether it signaled a rollback of certification requirements.
Healthesystems contends that the removed language does not eliminate the requirement to utilize certified interpreters, as the MPN proposal continues to apply interpreter standards from Labor Code §4600, ensuring all certified interpreter types are recognized, including interpreters certified to perform medical interpretation.
Reinforcing the continued importance of certified interpreters is a new data field within the service provider file submission, specifically requiring each interpreter’s certification number. These service provider files are sent to DWC as part of the application/reapproval process.
Others also expressed concerns about the newly proposed language regarding contracting requirements, noting that its adoption could lead to conflicting or overlapping regulations, as network contracting standards are already governed by the Department of Managed Health Care and the Department of Insurance.
There were also concerns about rural healthcare access standards and the use of telehealth providers to meet those standards, emphasizing the need for greater clarity on how telehealth can be leveraged to satisfy network adequacy requirements.
The DWC plans to release another draft for public review before initiating a formal rulemaking and Healthesystems will continue to report on new developments.
