The 2024 Section 1557 final rule added a definition almost nobody has written about. It sits in the definitions section between machine translation and qualified interpreter, and it names a mode of interpreting that most practice administrators have used without knowing it had a name.
If your patients don’t include those language groups, this is still worth ten minutes… because the definition tells you something about how HHS thinks about who counts as qualified.
What is relay interpretation?
Relay interpretation is interpreting from one language to another through an intermediate language. Under 45 CFR 92.4, the first interpreter listens to the speaker and renders the message into the intermediate language, and the second interpreter receives it in that intermediate language and interprets it into a third language for someone who speaks neither of the first two.
The rule also says where this mode is used. It is often used for monolingual speakers of languages of limited diffusion, including select indigenous languages.
Two interpreters, three languages, one conversation. That is the whole concept.
What the 2024 rule actually added
Relay interpretation had no definition in the 2020 rule. The 2024 final rule added one, and it also built relay into the qualification standard for interpreters.
The definition of a qualified interpreter for an individual with limited English proficiency at 92.4 now carries a parenthetical in each element. An interpreter must have demonstrated proficiency in speaking and understanding both English and at least one other spoken language, and qualified interpreters for relay interpretation must demonstrate proficiency in two non-English spoken languages. They must interpret effectively, accurately, and impartially to and from those languages and English, or between two non-English languages for relay interpretation.
That is a real standard. It means the Spanish-speaking half of a relay chain is held to the same bar as any other qualified interpreter, and being the only person available who speaks both Spanish and Mam does not make someone qualified under the rule.
When a clinic actually runs into relay interpreting
The scenario is more common than the term suggests, particularly in agricultural regions, in parts of Florida, California and the Carolinas, and in any FQHC or community clinic serving recent arrivals from Central America.
A patient speaks Mam, K’iche’, Q’anjob’al, Mixtec or Zapotec. They may also speak some Spanish, often not enough for a medical conversation. There is no English to Mam interpreter available on your line at 9am on a Tuesday. What is available is a Mam to Spanish interpreter and a Spanish to English interpreter, so the message runs through Spanish to reach the clinic.
Three practical points follow.
It is slower, and that is unavoidable. Every exchange passes through two interpreters. Build the appointment length around that rather than fighting it.
Accuracy risk compounds. Each handoff is a chance for something to be dropped. The rule’s requirement to interpret without changes, omissions or additions applies to both interpreters in the chain, which is exactly why the qualification standard matters more here, not less.
Do not use Spanish as a shortcut. The temptation with a Mam-speaking patient who has some Spanish is to run the whole conversation in Spanish and hope. That is not relay interpreting. It is interpreting into a language the patient has limited proficiency in, and it puts you back at the start of the same obligation.
Relay interpreting is not the same as an AI interpreter
This distinction matters and it gets muddled in vendor material, so it is worth stating plainly. An AI phone interpreter carries one language pair: your English-speaking employee and a patient speaking Spanish or Brazilian Portuguese. There is no intermediate language and there is no second interpreter, so it is not relay interpretation as the rule defines it.
It is the honest boundary of the product category.
Traditional interpreter companies add a third person to the phone call. AI companies replace the employee entirely. Interpreterly does neither. The employee stays on the call and we carry the language, in Spanish and Brazilian Portuguese, with Haitian Creole coming soon. For a Mam-speaking or K’iche’-speaking patient, the right answer is a human interpreter network that can build a relay chain, and no honest reading of the rule says otherwise.
The practical position for a multi-site clinic is both. Routine, high-volume calls in your top languages run one way. Rare languages, relay chains, informed consent and complex clinical conversations run through qualified human interpreters. If you are working out where the line sits for your own call mix, our compliance approach sets out what we do and do not cover, and you can always ask us about your languages before you assume a language is supported.
What to write into your language access procedure
The written language access procedure required by 45 CFR 92.8(d) has to describe how an employee obtains the services of qualified interpreters. If any part of your patient population speaks a language of limited diffusion, that procedure should say so specifically.
Four lines to add:
- Name the languages in your patient population that cannot be served by your primary interpretation vendor. Ask the vendor directly which of them they can and cannot cover, and get the answer in writing.
- Name who to call for a relay chain, with a route that does not depend on one person’s memory.
- Record the expected connect time. If a relay chain takes twenty minutes to assemble, the front desk needs to know that before booking a fifteen-minute slot.
- State that a patient’s partial proficiency in a pivot language is not a substitute for interpreting into their primary language.
None of that requires new technology. It requires the procedure to be honest about the gap.
Why the definition is worth your attention even without indigenous-language patients
The relay definition tells you how HHS reasons about qualification. The rule extended the qualified interpreter definition to cover the interpreter who never touches English at all.
The direction is consistent across the rule. Interpretation must come from a qualified interpreter under 92.201(c)(1). Bilingual staff count only as qualified bilingual staff, a category with its own defined test. Staff outside those categories may not be relied on at all under 92.201(e)(4). And where the interpretation arrives over audio, 92.201(g) sets quality conditions on the audio itself.
Read together, the rule cares less about the modality and more about whether the person carrying the language meets a standard and whether the patient can genuinely be understood. That is a useful frame for any language access decision you make this year, including the ones that have nothing to do with relay.
Frequently asked questions
What is relay interpretation in healthcare?
Relay interpretation is interpreting from one language to another through an intermediate language. Under 45 CFR 92.4, a first interpreter renders the message into the intermediate language and a second interpreter carries it into a third language. It is commonly used for speakers of languages of limited diffusion, including select indigenous languages.
Does Section 1557 allow relay interpretation?
The 2024 final rule defines relay interpretation and includes qualified relay interpreters within the definition of a qualified interpreter. Interpreters working in relay must demonstrate proficiency in two non-English spoken languages and meet the same accuracy, impartiality and ethics requirements as any other qualified interpreter.
Is relay interpreting the same as double interpreting?
The terms are used interchangeably in the industry. The rule uses relay interpretation and describes the same two-interpreter, intermediate-language structure.
Can an AI interpreter provide relay interpretation?
Interpreterly interprets between English and a supported language, currently Spanish and Brazilian Portuguese, with Haitian Creole coming soon. It does not route through an intermediate language and is not a relay interpreting service. For languages of limited diffusion, a human interpreter network that can assemble a relay chain is the appropriate route.
Which languages usually need relay interpreting in US clinics?
Most often indigenous languages of Guatemala and Mexico, including Mam, K’iche’, Q’anjob’al, Mixtec and Zapotec, where Spanish is used as the intermediate language. Availability varies by vendor and by time of day, so confirm coverage with your vendor rather than assuming it.
