In March 2025, the U.S. government promulgated Executive Order 14224, declaring English the official language of the United States and instructing federal agencies to rescind prior language‑access guidance. The order replaced the long‑standing Executive Order 13166, which had required federal agencies to work with funding recipients to ensure that individuals with limited English proficiency (LEP) have “meaningful access” to government services. Because EO 14224 directs agencies to reevaluate their multilingual programming and withdraw guidance, some healthcare providers have asked whether their duty to provide interpreters and translated materials still stands. The short answer is that Title VI of the Civil Rights Act of 1964 and Section 1557 of the Affordable Care Act (ACA) continue to impose robust language‑access obligations on any health program receiving federal financial assistance. Executive orders cannot override statutes; thus, providers must still offer free language services to LEP patients, ensure interpreter competence, and translate vital documents.
This article explains what Title VI and Section 1557 require in practice, how EO 14224 changes the federal landscape, and what healthcare organizations should do to remain compliant. It draws on analysis from the Kaiser Family Foundation (KFF) and guidance from the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR), which enforces these civil‑rights laws. It also situates language access within the larger context of demographic change: more than 27 million Americans—about 9 % of the population—are LEP, and they are disproportionately immigrants, Asian and Hispanic individuals, and lower‑income families.
Title VI: Prohibiting National‑Origin Discrimination
Title VI prohibits discrimination based on race, color and national origin in programs that receive federal funds. Although the text does not explicitly mention language, courts and federal agencies have long interpreted discrimination based on national origin to include denying services to individuals because they do not speak English. In the late 1970s and 1980s, the U.S. Department of Justice (DOJ) issued guidance clarifying that Title VI required recipients of federal funds to take reasonable steps to provide language assistance. Executive Order 13166, issued in 2000, codified this interpretation across federal agencies, but its revocation does not dismantle Title VI’s underlying obligations.
Under Title VI, health providers must ensure meaningful access to care for LEP patients. HHS’s OCR advises covered entities to assess factors such as the number and proportion of LEP individuals they serve, the frequency of encounters, the importance of the service and available resources. When a substantial portion of a provider’s patients are non‑English speakers, the provider must offer comprehensive language services. Key requirements derived from Title VI include:
- Free language assistance. OCR explains that entities receiving HHS funding must offer interpreter and translation services at no cost to LEP individuals. Charging patients for interpreters or passing costs onto insurers is considered discriminatory.
- Qualified interpreters and translators. Using family members, friends or ad hoc bilingual staff for medical interpretation can lead to errors and breaches of confidentiality. Title VI requires providers to furnish trained interpreters who are proficient in both languages, understand medical terminology, and are aware of ethical and cultural considerations.
- Translation of vital documents. Consent forms, intake paperwork, discharge instructions and notices of privacy practices must be translated into languages commonly used by patients. This ensures that patients can make informed decisions about their care.
- Notifying patients of their rights. Providers should post signage in multiple languages and include notices on their websites informing patients that free language assistance is available.
- Developing and maintaining a language‑access plan. Covered entities should document how they will identify LEP individuals, provide interpreters, translate materials, train staff and monitor program effectiveness. This plan should be reviewed periodically as patient demographics and resources change.
Section 1557: Strengthening Protections in Health Programs
The ACA’s Section 1557 extends civil‑rights protections into the healthcare arena by prohibiting discrimination in any health program or activity receiving federal financial assistance on the basis of race, color, national origin, sex, age or disability. Section 1557 explicitly incorporates Title VI and affirms that entities must take reasonable steps to provide meaningful access for LEP individuals. In 2016, the Obama administration issued regulations implementing Section 1557, requiring covered entities to post nondiscrimination notices and taglines in multiple languages. Subsequent administrations modified these regulations, but the fundamental requirement of language access remained. In 2024, the Biden administration finalized new Section 1557 rules reaffirming that language‑access obligations apply to hospitals, clinics, insurers and state Medicaid programs.
Section 1557’s regulations clarify that providers must:
- Provide language assistance timely and free-of-charge manner. Services must be offered at the time they are needed, during appointments or while delivering care, and cannot be billed to the patient.
- Translate “vital” written materials and post notices of availability. Vital documents include those that inform individuals about how to obtain services or describe their rights and responsibilities. Providers must also display a notice of nondiscrimination in prominent locations and on websites.
- Ensure accuracy and quality. Section 1557’s rules caution against using machine translation without human review because inaccuracies in medical translations can harm patients.
- Designate a language‑access coordinator. Entities with more than 15 employees must appoint an individual responsible for ensuring compliance, handling grievances and training staff.
- Adopt policies and procedures. Written policies should describe how staff will identify language needs, request interpreters, monitor interpreter performance and provide translated materials.
By incorporating Title VI and applying to any health program receiving federal funds—including Medicaid, Medicare Advantage, the Children’s Health Insurance Program (CHIP) and the Health Insurance Marketplaces—Section 1557 ensures that language access is a fundamental civil‑rights requirement across the healthcare landscape.
Executive Order 14224: A Change in Agency Guidance, Not Statutory Law
Executive orders guide executive agencies in implementing federal law but cannot repeal or amend statutes. EO 14224 instructs agencies to prioritize English and withdraw prior language‑access guidance. In compliance, the DOJ rescinded its 2022 LEP guidance, took down LEP.gov, and signaled it would no longer pursue cases alleging disparate impact discrimination due to language barriers. The order also encourages agencies to shift resources away from providing materials in multiple languages. These changes may reduce federal support and oversight for language services, causing confusion among providers.
However, the executive order does not—and cannot—eliminate the requirements of Title VI or Section 1557. Statutory obligations remain intact, and providers that curtail language services in response to EO 14224 risk violating civil‑rights laws. Courts have long held that executive orders cannot contradict statutes; only Congress can repeal or amend Title VI and Section 1557. Therefore, health providers should view EO 14224 as a shift in federal agencies’ priorities, not a license to reduce language access.
Practical Implications for Healthcare Providers
Legal and Financial Risks
Noncompliance with Title VI and Section 1557 can lead to significant consequences. Patients, advocacy organizations or staff can file complaints with HHS’s OCR, which has the authority to investigate, resolve disputes and recommend termination of federal funding. Although the DOJ may now focus less on disparate‑impact cases, intentional discrimination remains prohibited, and OCR continues to enforce language‑access requirements. Providers may also face lawsuits under state or federal law and could incur malpractice liability if miscommunication leads to harm.
Moreover, several states—such as California, New York and Maryland—have their own language‑access laws that are stricter than federal requirements. Failing to provide language services in these states could lead to additional penalties. Investing in interpreters and translated materials can reduce readmissions, improve adherence and mitigate legal risks, making compliance not only a legal mandate but also a financially prudent choice.
Updating Language‑Access Plans
Given the evolving policy environment, providers should review and strengthen their language‑access plans. Recommended steps include:
- Conduct a language needs assessment. Analyze patient demographics to determine the most frequently spoken languages. Prioritize languages based on the number of LEP patients and the importance of the services offered.
- Maintain a roster of qualified interpreters. Providers can hire in‑house interpreters, contract with telephone or video‑interpretation services, or participate in language‑service cooperatives. Ensure interpreters are trained in medical terminology and confidentiality.
- Train staff on procedures. Educate all staff—from front desk personnel to clinicians—on how to identify language needs, request an interpreter, document interpreter use and respect patient privacy.
- Translate and review documents. Regularly update translated forms and educational materials to reflect changes in medical practice and patient needs. Have bilingual experts review translations to ensure accuracy.
- Notify patients of available services. Post multilingual notices in waiting areas, exam rooms, registration materials and on websites. Provide taglines in common languages that explain how to request an interpreter.
- Monitor and evaluate services. Track interpreter use, wait times, patient satisfaction and outcomes. Solicit feedback from LEP patients to identify gaps and improve services.
- Designate a compliance officer. Larger organizations should appoint a language‑access coordinator responsible for overseeing training, developing policies, handling grievances and staying abreast of regulatory changes.
Leveraging Technology Wisely
Advancements in artificial intelligence (AI) and machine translation have generated new tools for communication. These technologies can supplement but not replace qualified interpreters. For example, AI can provide initial translations for low‑risk interactions or administrative messaging. However, Section 1557 warns against relying solely on machine translation for medical documents. Providers should use technology judiciously, employ human review to ensure accuracy and treat machine translation as an aid rather than a substitute for professional interpretation. Hybrid models—where AI triages requests before connecting patients to interpreters—can improve efficiency without compromising quality.
Conclusion: Language Access as a Pillar of Equitable Healthcare
Executive Order 14224 introduces uncertainty into federal language‑access policy, but it does not diminish the statutory obligations of healthcare providers. Title VI still prohibits discrimination based on national origin and requires reasonable steps to ensure meaningful access for LEP individuals. Section 1557 reinforces those protections and expands them across all health programs receiving federal funds, mandating free, timely and accurate language assistance. These statutes remain in force regardless of executive‑level shifts.
As the U.S. population continues to diversify, the need for language‑accessible healthcare will only grow. More than 27 million people already rely on interpreters and translated materials to communicate with clinicians. Ensuring meaningful access is not merely a regulatory requirement; it is a cornerstone of patient safety, quality care, and health equity. By investing in language services, training staff, and adopting thoughtful technology strategies, healthcare providers can uphold civil‑rights protections, foster trust with diverse communities, and deliver care that truly meets patients’ needs—no matter what language they speak.