The 2025 Claims Working Group for the Workers’ Compensation Insurance Rating Bureau of California (WCIRB) highlights that California’s linguistic diversity has become a primary driver of rising Loss Adjustment Expenses (ALAE) within the state’s workers’ compensation system.
“There has been significant growth in physical medicine and rehabilitation service costs (included in physician and non-physician practitioner services) and interpreter and home health care service costs,” states the WCIRB advisory on pure premium rates effective September 2025.
Interpreter Demand Surge
To uphold due process for working-age Californians who speak a language other than English at home, the Department of Workers’ Compensation (DWC) mandates interpreter presence at all medical treatment appointments, legal depositions, and hearings.
This systemic integration is most visible in high-intensity regions like Los Angeles County, where Spanish-speaking interpreters are requested by the party needing interpreting services. Demand is fueled by a surge in cumulative trauma claims within industries such as agriculture and construction that employ high concentrations of limited English proficiency (LEP) individuals.
The NCTA has documented numerous incidents where non-certified individuals were erroneously permitted to interpret at these frequent workers’ compensation evaluations, which by law are reserved for highly qualified, fully certified interpreters.
The issue is not just the lack of full certification, but also how those credentials are presented. Certification advocates allege that a number of HUB-CMI credential holders are intentionally misrepresenting themselves as “fully certified” to medical office staff.
Major Difference in Credentials
HUB-CMI is a preliminary, non-renewable entry-level interpreting credential. It indicates that an individual has passed a written examination in English only, demonstrating a baseline knowledge of the medical interpreting profession.
Holders of this credential have two years to pass the oral and interpreting components to achieve full certification. Per NBCMI policy, no language designation is added to the HUB-CMI title.
CMI (Certified Medical Interpreter) is the full certification granted by the NBCMI. It requires passing both the written exam and a rigorous oral examination in a specific language (e.g., Spanish, Russian, Korean). The proper credential designation includes the language, such as “CMI-Spanish.”
Advocates for certified interpreters argue that credential misrepresentation, including expired pre-certification status, is a direct violation of the NBCMI’s own Disciplinary Policy, which lists “Fraud or misrepresentation of the NBCMI credentials” as grounds for sanctions.
“It would be simply devastating to see NBCMI or other certified interpreters — who have spent considerable resources on training and testing — be replaced by those who have not yet attained the appropriate credentials.” — Lorena Ortiz Schneider, Founder, Interpreter & Translator
The scope of the issue is illustrated by dozens of documented incidents. One HUB-CMI individual, for example, was reportedly identified at Qualified Medical Evaluation (QME) assignments 12 times between 2024 and 2025 in locations ranging from Van Nuys to Simi Valley.
Outcomes varied wildly; in some cases, the doctor deferred to an attorney, while in others, the HUB-CMI interpreter interpreted during the entire medical-legal exam. Certified interpreters are frustrated and have voiced their concerns to the NBCMI.
“I didn’t earn my certification lightly. I paid good money and years of training to attain that credential. When the NBCMI declines to even hear my complaint or act on repeated reports that HUB holders are misrepresenting credentials, it sends a clear message that the standards behind that certification don’t matter,” commented Carrie Catena, NBCMI.
Marcia Delacey López, CCHI, echoed the sentiment: “It took me many years to get certified. Hours of training, miles driving to school. Three years later, I passed the test, not only for myself but to provide concise and accurate interpreting service for doctors and patients. HUB Interpreters are creating a very difficult environment for all of us.”
About the NBCMI response, Certified Medical Interpreter Claudia Keossian stated that “it is frustrating to see how the same entity that controls the certification process is unable to hear complaints from certified interpreters who invest time and money in the entire process of getting certified.”
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But interpreters are not alone in their concerns. The California Applicants’ Attorneys Association (CAAA) sent a briefing in December 2025 to its members, highlighting the seriousness of this issue.
In the briefing shared with Slator, the organization urges its members to carefully check interpreter credentials to protect injured workers’ rights, maintain the integrity of the medical-legal evaluation process, and defend against broader attacks on immigrant communities.
Slator also reached out to NBCMI Chair, Joanna Larson, who commented that the organization has had several communications with the NCTA, as well as individuals who have contacted the National Board separately.
Larson added that “the National Board has emphasized that, as a certification body, we do not have the power to oversee the types of assignments that an interpreter takes. We have recommended that these concerns be taken to the relevant state body that oversees this legislation. Additionally, we have reminded CMI and HUB-CMI interpreters that they are responsible for being familiar with and abiding by any local laws in the area or areas that they serve.”
“It is frustrating to see how the same entity that controls the certification process is unable to hear complaints from certified interpreters who invest time and money in the entire process of getting certified.” — Claudia Keossian, Certified Medical Interpreter
What Is at Stake?
For starters, costs. California Workers’ Compensation Law requires employers to authorize up to USD 10k in medical treatment within one day of a claim being filed, even while the claim is still under investigation. As such, a claim is considered by insurers as a high-stakes interpreting scenario where precision is paramount.
Second, legislation. California Code of Regulations Section 9795.1.6 requires interpreters at medical-legal exams to be fully certified. Despite this law, evidence compiled by CMIs suggest a “systematic encroachment” of interpreters holding the HUB-CMI into high-stakes QMEs.
Third, medical interpreting certification is itself at stake. Certified interpreters contend that credential misrepresentation results in devaluation of certification and a potential risk to the quality of care for LEP injured workers.
“It would be simply devastating to see NBCMI or other certified interpreters — who have spent considerable resources on training and testing — be replaced by those who have not yet attained the appropriate credentials,” stated Lorena Ortiz Schneider, a leading advocate for California certified interpreters.
In California, QME exams help determine the permanent disability status and financial future of injured workers, and these evaluations require specialized knowledge from interpreters. Some QME offices have expressed frustration over interpreting agencies overlooking this fact.
In many instances, staff are left in a legal gray area when an unqualified interpreter arrives. While some offices turn them away, others, confused by the terminology, allow the examinations to proceed, potentially jeopardizing the legal validity of the evaluation.
For the LEP worker, the stakes are existential. An inaccurate interpretation during a QME can lead to a misdiagnosis or an undervalued settlement.
As the backlog of workers’ compensation cases grows, the push for clarity continues. For California’s certified interpreters, the goal remains simple: ensuring that the law is followed and that the health, well-being, and dignity of injured LEP workers are not overlooked.
