Two things are happening to your non-English calls at once. The quality measure that tracked them is disappearing. The civil-rights law that governs them isn’t.
CMS is removing the call center interpreter and TTY measure from Star Ratings. For years, that measure was the closest thing most plans had to a language-access scorecard. Lose it, and it’s tempting to think the pressure is off.
It isn’t. Section 1557 of the Affordable Care Act still requires meaningful access for members with limited English proficiency, and it’s enforceable by regulators and by members in court. The obligation didn’t shrink. Your scorecard did.
Here’s the mechanism that should worry you. Your non-English calls are the ones your QA reviews least, because reviewers score in the languages they speak. So the interactions carrying the most legal exposure are the ones you watch the least. The fix isn’t a new metric. It’s scoring 100% of calls, in every language.
What Changed, and What Didn’t
CMS is removing the call center foreign-language interpreter and TTY availability measure from Star Ratings, starting with the 2028 Star Ratings.5 That measure scored whether a caller could actually reach an interpreter and whether TTY worked. For many plans, it was the only language-access number on the board.
Lose it, and the quarterly metric goes away. The duty behind it doesn’t.
Section 1557 still governs language access, and its rules are fully in force. A federal court vacated parts of the 2024 final rule, but only the gender-identity provisions. A June 2026 Federal Register notice confirmed the rest of the rule, language access included, remains in force.2
So the obligation didn’t change. The reminder did. And it covers nearly everyone: any health plan that takes federal funds, across Medicare Advantage, Medicaid managed care, and the Marketplace.
What Section 1557 Actually Requires
The rule is specific, and it’s about more than having a phone line.
Covered plans must take reasonable steps to provide meaningful access for members with limited English proficiency, and post notice that free language help is available.1 Written language-access procedures, staff training, and that notice were due by July 5, 2025.1
The interpreter standard is where plans get exposed. A qualified interpreter has to be accurate, impartial, and fluent in the specialized vocabulary. HHS has been explicit that a person’s self-identified proficiency alone isn’t enough, and bilingual staff can’t act as interpreters unless they meet that standard.3
So “we have Spanish-speaking agents” isn’t compliance. Neither is “we bought an interpreter line.” The question is whether qualified interpretation actually happened on the call, and whether you can show it.
And 1557 has teeth. OCR enforces it, and members can sue under it directly. The calls that carry that exposure are the ones your QA reviews least.
The Members This Covers
More than 25 million people in the United States are limited English proficient.4 Across Medicare Advantage, Medicaid, and the Marketplace, they’re a large share of who you serve.
Those members call. Their calls get handled. Then they disappear from quality review, because the people scoring calls read and speak English.
What This Looks Like in Practice
The typical setup looks compliant on paper. The plan staffs bilingual agents, contracts a phone interpreter service, and files its written procedures. The box is checked.
Then QA runs. It pulls a monthly sample, scores each call, and because the reviewers work in English, the sample is English. The Spanish, Mandarin, and Vietnamese calls go unscored. Nobody checks whether the interpreter was qualified, whether the member understood their benefits, or whether the call went sideways.
Now a complaint lands, or OCR asks for evidence of meaningful access. What can the plan produce? A contract and an invoice for the interpreter line. Not a record of what happened on the member’s actual call.
That gap is the risk. The obligation runs on every non-English call. The evidence runs on almost none of them.
The difference between the two approaches is whether you can show what happened on a non-English call, or only that you paid for a line.
What to Look for in a Solution
When you evaluate how your plan handles non-English calls, look for five things.
- Every language scored, not just English. Translation and scoring built in for all languages, so non-English calls are reviewed on the same footing as English ones.
- A record of the interaction, not a vendor’s assurance. An actual transcript and score for the call, not a line-item on an invoice.
- Evidence you can produce, not a contract and an invoice. Proof that meaningful access happened, ready if OCR or a member asks.
- Compliance scored on the call, not inferred from a purchase. Language-access handling evaluated on each interaction.
- Plan-owned data, not vendor custody. The transcripts and scores sit with the plan.
The through-line is proof. Meaningful access is a legal duty, so you want to show it happened, not assume it did.
Mizzeto’s Call Center Intelligence Tool scores 100% of calls with translation built in for every language, and its CMS & HIPAA Compliance dimension evaluates language-access handling on each one. If OCR or a member ever asks, the record is yours.
What’s Left When the Scorecard Is Gone
The Star measure’s exit removes a reminder, not a requirement. We wrote about what its removal means for your call center: Fewer Star Ratings Measures, Higher Stakes for Your Call Center.
The plans that read the change as permission to stop watching non-English calls are the ones taking on risk. The plans that score every call, in every language, keep both the compliance evidence and the member experience, no matter which measures CMS keeps or cuts.
If you want to see what’s happening on your own non-English calls, send us a sample. We’ll return scored transcripts, in the member’s language and in English.
References
- Federal Register, 89 FR 37522 (May 6, 2024); 45 CFR Part 92 (Section 1557 final rule).
- Federal Register, 91 FR 32887 (June 2, 2026) (other provisions of the Section 1557 rule remain in force).
- U.S. Department of Health and Human Services, Office for Civil Rights. Dear Colleague Letter on Section 1557 Language Access, December 5, 2024.
- U.S. Census Bureau, American Community Survey.
- Centers for Medicare & Medicaid Services. Medicare Program; Contract Year 2027 Policy and Technical Changes (CMS-4208-F3), 91 FR 17384 (April 6, 2026). https://www.federalregister.gov/documents/2026/04/06/2026-06600/




















