Concerns are mounting among California’s certified medical interpreters about the growing misuse and misrepresentation of interpreter credentials in workers’ compensation medical-legal settings.

Since 2022, members of the Northern California Translators Association and its Workers' Compensation Interpreter Group have reported a pattern in which individuals holding only preliminary credentials are accepting assignments that state regulations reserve for fully certified medical interpreters. These concerns focus on the use of the HUB-CMI designation, a precertification status issued by the National Board of Certification for Medical Interpreters, which is being presented to medical offices and agencies as equivalent to full certification.

The distinction between credentials is significant. HUB-CMI is an entry-level, non-renewable credential indicating passage of a written English exam only, with a two-year window to complete the required oral and language-specific testing. By contrast, a fully certified medical interpreter holds the CMI designation tied to a specific language after passing both written and oral examinations.

Certified interpreters report that confusion, and in some cases alleged misrepresentation, has resulted in HUB-CMI holders being placed in high-stakes medical-legal evaluations, including qualified medical evaluations, despite California regulations requiring fully certified interpreters in those settings. The Northern California Translators Association offers a warning that this practice risks undermining both professional standards and the reliability of medical-legal communications.

The issue is happening at the same time interpreter demand is rising across California’s workers’ compensation system. With approximately 44% of California households speaking a language other than English at home, and millions of residents reporting limited English proficiency, interpreter services are now embedded across medical treatment visits, depositions and hearings. Interpreters have documented repeated situations where noncertified or precertified interpreters were allowed to proceed with medical-legal exams, sometimes due to scheduling pressure or staff misunderstanding of credential terminology. Certification bodies note that they cannot control assignment practices directly and have urged stakeholders to raise enforcement concerns with state regulators.

An interpreter’s qualifications directly affect due process, the integrity of QME and medical-legal reports, and the defensibility of the record. An inaccurate interpretation can distort medical histories, mechanism-of-injury descriptions, symptom reporting and functional limitations, all of which shape disability ratings and overall case value. Attorneys should carefully verify interpreter credentials in advance, confirm full certification and language designation, and object on the record where requirements are not met. Careful credential checking not only protects injured workers with limited English proficiency, but also helps preserve the validity of evaluations and reduce the risk of disputes over flawed exams.

This opinion by the California Applicants' Attorneys Association communications team is republished, with permission, from the CAAA website.