Policy Development

Introduction

There is an increasing expectation that Primary Care Agencies will be able to quantify and demonstrate how they ensure that services are accessible and responsive to the needs of the culturally and linguistically diverse communities they serve. Agencies will be subject to a range of standards of standards and accreditation process which assess agency performance in meeting these expectations.

The Government is committed to providing accessible services to all Victorians. As part of this commitment, clients not able to communicate through written or spoken English should have access to professional interpreting and translating services:

  • when required to make significant decisions concerning their lives or

  • where essential information needs to be communicated to inform decision making

Government policies can be found at:

Definitions and Quality Standards

Agency policy provides the broad framework in which best-practice approaches to quality language service provision can occur. Policies identify agreed principles which guide decision making and seek to ensure that agreed standards are consistently applied throughout all aspects of service to consumers, their carers and community. In general, policies address questions of what our position is and why, and procedures address questions of who, what, when and how a policy will be implemented.

Policy Considerations

When developing a policy, it is important to identify the scope of the policy; the principles underpinning the policy; and to identify any contentious issues that should be addressed through the policy. Questions to be answered include:

  • Is the policy organisation-wide and does it compliment the existing multicultural or language policies of the organisation?

  • Is the policy about language services specifically or is it about responding more broadly to cultural as well as linguistic diversity?

  • Will there be one policy to cover interpreters, translations and ethnic media or will a policy be developed for each area?

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  • Who does the policy apply to and how will it be used in your organisation?

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  • What are the key definitions, abbreviations and references that will be used?

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  • Will the policy address contentious issues?

Principles and Standards

There are a range of standards and principles to be considered when developing or reviewing policies in relation to language service provision. The following list of questions is designed to help you think about the principles and standards to include in your agencies policy:

  • Does the organisational policy reflect government policy on language services?

  • How does/will the policy reflect your agencies mission and values?

  • What are the risk management considerations & duty of care obligations that need to be addressed?

  • Will the policy address social justice principles of access, equity and participation?

  • Does the policy need to recognise achievement of quality, industry and accreditation standards?

  • What are the legislative requirements that must be complied with?

  • Are there any specific accountability requirements of funding bodies that need to be reflected in the policy?

  • How are consumer rights and responsibilities to be reflected in the policy?

In keeping with the commitment to be practical, a list of references as a footnote to policy documents is recommended, rather than a detailed description or regurgitation of principles and standards which may be better described in their source documents. The list of references provided in the Bibliography provides a useful starting point for identification and clarification of values and principles in relation to language services.

The “Must, Should, Could” test is a useful way of sorting through the sometimes daunting range of principles, standards, and issues to be considered, and help to set meaningful policy direction. Asking the question "What are the obligations which must be achieved, and achieved consistently?” can help to prioritise those principles and issues at the core of agency policy. Ranking other issues in the “should” and “could” categories can draw attention to the things that you aspire to as an organisation, while at the same time recognising that policies can be reviewed and up-dated over time as agency capacity evolves and matures.

Contentious Issues

From our consultations with member agencies, a range of contentious issues have been
identified. They include:

How agencies make decisions about the best use of scarce resources for language
services?

Will the policy address issues of effective control of scarce resources for language service
provision?

Will the policy address the agencies position in relation to?

  • The use of bi-lingual staff as interpreters and translators?

  • The use of family members as interpreters

  • The use of professional interpreters and translators.

To help you think about your agencies position on these issues, examples of “Policy
Considerations” are highlighted in the toolkit.

Procedures and Guidelines

This toolkit provides the appropriate guidelines, procedures and instructions necessary for agencies to effectively deal with the broad range of language services issues. Many have been provided as a series of 'take away' forms which service providers can use when dealing with clients without direct reference to the toolkit.

Procedures address the questions of:

  • Who will do it?

  • What will they do?

  • When will they do it?

  • How it will be done?

The range of procedures you require will depend on the scope of your agency policies. The following sections of this toolkit include some examples of procedures in relation to language services:

Interpreting

  • Identifying the need for an interpreter or

  • Recognise the interpreter card

  • Booking an interpreter

  • Translators
  • Commissioning translations

  • Other Issues
  • Seeking funding and access to fee-free, interpreting and translation services

  • Budgeting and funding for language services

  • Collection of data including introduction of client data profiles, utilisation rates of
    language services to enable evaluation and planning

Recording the need for an interpreter on the patient’s file and establishment of a system where an interpreter will be automatically arranged at subsequent visits. See also “Interpreter and translator reporting proforma” www.dhs.vic.gov.au/multicultural. This is a form used by DHS departments which can be adapted for agency use.

Minimum requirements for Department of Human Services programs and funded agencies

To comply with Government policy as outlined in the VOMA Guide and DHS Language
Services Policy, all departmental programs and funded agencies must have policies and
procedures in place to meet three minimum language services requirements as stated in
the DHS Language Services Policy.

Requirement 1
Clients who are not able to communicate through written or spoken English have access to
information in their preferred language at critical points. That is, when they:

  • need to be informed of their rights;

  • need to give informed consent; and,

  • need to be advised of critical information relating to their health and wellbeing and/or participate in decision making related to medical and other human service matters.

Requirement 2
Language services are provided by appropriately qualified professionals.

Requirement 3
Persons, including family members, under 18 years of age are not used as interpreters.