Language Access Compliance: Regulatory Updates | Q1 2026
Issue #1 | Q1 2026
At the request of our Client Advisory Board, BURG Translations developed this briefing to keep our clients informed about language access requirements that may affect your industries.
If 2025 felt like a difficult year to keep up with…well, it was. New federal legislation and active court settlements all took place in the same 18 months, just as much of the federal guidance (guidance documents, not the underlying statutes) that helps organizations navigate language compliance was formally withdrawn.
This issue covers regulatory changes, new legislation, enforcement actions, and legal developments across healthcare, life sciences, manufacturing, and legal services from 2025 through Q1 2026. A small number of items are from late 2024 and are included because they remain active or established enforcement patterns that continue to apply.
In This Issue
Regulatory Updates
- Executive Order 14224 | The “Official English” Policy
- The SPEAK Act | Telehealth Language Access Mandates
- Section 1557 | Language Access Requirements for Healthcare
- OSHA Hazard Communication Standard | Updated Training Deadlines
- ADA Title II Web Rule | Digital Accessibility for Government Entities
- HHS Section 504 | Digital Accessibility for Healthcare Organizations
- FDA Clinical Trial Guidance | Enrollment Practices and Language Access
- Joint Commission | New Accreditation Framework for Hospitals
- NPG.07.01.01 | Joint Commission National Performance Goal
- Language Access for All Act | Proposed Federal Legislation
Legal Developments
- Bayhealth Medical Center | February 2026
- Alameda County Sheriff’s Office | September 2024
- Freeport Police Department | December 2024
- MMG Fusion | March 2026
Key Compliance Deadlines: Q1 2026
The following deadlines and regulatory changes are active or approaching as of Q1 2026.
- Section 1557 compliance deadline, July 2025 (passed)
- Joint Commission NPG framework, active January 1, 2026
- ADA Title II web accessibility, April 24, 2026
- Section 504 healthcare digital accessibility, May 11, 2026
- OSHA HazCom employer training, November 20, 2026
Regulatory Updates
1. Executive Order 14224 | The “Official English” Policy
What Happened
On March 1, 2025, the administration issued Executive Order 14224, designating English as the official language of the United States. This order revoked the 25-year-old federal requirement (EO 13166) for agencies to maintain language access plans. By July 2025, the government had suspended LEP.gov, the central site for compliance manuals and data. On March 4, 2026, the Department of the Treasury officially canceled its Title VI language access guidance, which had been in place since 2005.
What the Law Says
Executive Order 14224 changed internal federal policy, but it did not repeal federal statutes. Organizations that receive federal funding are still legally required to provide meaningful access to services for individuals with limited English proficiency (LEP) under Title VI of the Civil Rights Act and Section 1557. These laws remain fully enforceable even though the government has removed the specific checklists and manuals that organizations once used to guarantee compliance.
BURG’s Perspective | What This Means for You
“Meaningful access” is a legal standard with a specific definition: Patients and their companions must be able to participate in your services as effectively as English-speaking, non-disabled individuals, a standard that applies to both limited English proficiency and disability-related communication needs. That requirement has not changed, but the federal guidance that helped organizations structure and document their compliance programs has been rescinded pending new DOJ direction.
For most compliance teams, that means taking a hard look at whether their current language access program can stand on its own without a federal checklist to measure it against.
Current Status
As of March 2026, federal compliance guidance for language access has been formally rescinded, and LEP.gov remains suspended pending new DOJ guidance. Language access plans built on the underlying statutes remain valid. What organizations have lost is the federal framework they used to structure, document, and measure their compliance programs against, and no replacement guidance is yet in place.
2. The SPEAK Act: Technical Mandates for Telehealth
What Happened
On February 3, 2026, the SPEAK Act became law as part of the Consolidated Appropriations Act. The law directs HHS to develop and publish guidance on language access for telehealth by February 2027. When finalized, that guidance will give federally funded health systems a clearer framework for meeting their existing obligations under Section 1557.
What the Law Says
The SPEAK Act directs HHS to develop and publish guidance on telehealth language access by February 2027. The guidance is expected to address key parts of the telehealth experience, including communications before, during, and after visits.
The law requires HHS to develop the guidance in consultation with relevant stakeholders, including language-access experts if specified in the final text. This could give language-access stakeholders a greater role in shaping future federal telehealth guidance.
BURG’s Perspective | What This Means for You
Most health systems already must comply with Section 1557 obligations related to language access in telehealth. The SPEAK Act suggests that additional federal guidance on telehealth language access is forthcoming. Health systems with platforms that were not built with language access in mind may need significant updates to meet the 2027 guidance.
Current Status
The SPEAK Act is now in effect. HHS has until February 3, 2027, to publish its telehealth language-access guidance. The new HHS guidance is not yet in place, but covered health systems remain subject to existing Section 1557 obligations.
3. Section 1557: Language Access Requirements for Healthcare
What Happened
On May 6, 2024, HHS published a final rule under Section 1557 of the Affordable Care Act establishing more robust requirements for language access in healthcare. The deadline for compliance was July 5, 2025. For healthcare organizations that receive federal funding, which includes virtually every hospital, clinic, and health plan that accepts Medicare or Medicaid, those requirements are now in effect.
What the Law Says
The 2024 final rule requires covered entities to maintain written language access policies and procedures, provide multilingual notices of available language services in the top 15 languages spoken in their state, use only qualified interpreters, prohibit reliance on family members or untrained staff for interpretation, and ensure that machine translation of critical documents is reviewed by a qualified human translator. Organizations with 15 or more employees need to designate a Section 1557 Coordinator responsible for overseeing compliance.
BURG’s Perspective | What This Means for You
Section 1557’s language access requirements are statutory, meaning they exist independent of which administration is enforcing them, and of the federal guidance changes described earlier. Healthcare organizations that delayed implementation on the assumption that the current administration would roll back these requirements are carrying unresolved legal exposure. Private litigation under Section 1557 does not require federal enforcement action to proceed.
Current Status
In May 2025, HHS announced it would not enforce provisions of the 2024 rule related to gender identity and pregnancy status. The language access requirements are not affected by that decision. They are still in full effect, and the statute itself has not changed.
4. OSHA Hazard Communication Standard: Updated Training Deadlines
What Happened
OSHA’s updated Hazard Communication Standard introduces new requirements for how chemical hazards are classified, how Safety Data Sheets are structured, and what appears on container labels. The compliance deadlines are phased by organization type. Chemical manufacturers, importers, and distributors evaluating substances must comply by May 19, 2026. Employers have until November 20, 2026, to update workplace labeling, hazard communication programs, and employee training (or multilingual training materials) for substances.
What the Law Says
The updated standard requires employers to retrain employees whenever new chemical hazards are introduced or hazard information changes. OSHA’s training requirement has a straightforward interpretation: training means presenting information in a manner that employees are capable of understanding. That standard applies to the updated HazCom training as it does to all safety instructions under 29 CFR 1910.1200.
BURG’s Perspective | What This Means for You
When Safety Data Sheets and hazard classifications change, employee training has to reflect those changes. For manufacturing operations with multilingual workforces, updating a HazCom program means updating the training materials workers actually use, in the languages they speak. That is what OSHA compliance officers look for when they assess whether training was genuinely received.
Current Status
OSHA extended all compliance deadlines by four months in January 2026 to allow time for additional guidance, and was explicit that the extension was not a signal of reduced enforcement expectations. The November 20, 2026, employer training deadline is the one most directly relevant to operations teams.
5. ADA Title II Web Rule: Digital Accessibility Deadline for Government Entities
What Happened
In April 2024, the Department of Justice published a final rule establishing specific technical standards for how state and local government websites and mobile applications must function for people with disabilities. For the first time, the rule sets a concrete, enforceable benchmark: Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA. The first major compliance deadline is April 24, 2026 for government entities serving populations of 50,000 or more.
What the Law Says
The rule applies to all digital services through which a state or local government delivers programs, services, or activities. WCAG 2.1 Level AA is the international standard that determines whether a person with a disability is able to use a website or mobile app to access the services they need.
It covers websites, mobile apps, online forms, digital documents, and third-party platforms operating on a government entity’s behalf. If a government agency contracts with a software vendor to run a patient portal, scheduling system, or public health platform, that vendor’s product must meet WCAG 2.1 Level AA. The government entity retains legal responsibility regardless of whether the failure originates with a vendor.
BURG’s Perspective | What This Means for You
For healthcare organizations, public universities, courts, and other entities that receive or process government contracts, the procurement implications are immediate. Any digital platform you operate on behalf of a state or local government client must meet this standard by their deadline. An inaccessible portal is a non-compliant portal, and your client bears the legal risk.
A platform that fails basic accessibility standards is one that patients and residents with disabilities cannot effectively navigate. For organizations already managing Section 1557 language access obligations alongside ADA and Section 504 compliance requirements, the operational reality is the same: inaccessible digital infrastructure creates legal exposure across multiple frameworks simultaneously.
Current Status
The April 24, 2026, deadline applies to government entities serving populations of 50,000 or more. Smaller jurisdictions and special districts have until April 26, 2027. The rule is active and DOJ enforcement authority is in place.
6. HHS Section 504: Digital Accessibility Requirements for Healthcare
What Happened
On May 9, 2024, HHS published a final rule updating Section 504 of the Rehabilitation Act, establishing for the first time specific digital accessibility requirements for healthcare organizations that receive federal financial assistance. For organizations with 15 or more employees, the compliance deadline is May 11, 2026. Organizations with fewer than 15 employees have until May 10, 2027.
What the Law Says
The rule requires covered entities to bring their websites, mobile apps, and patient-facing kiosks into conformance with WCAG 2.1 Level AA – the same technical standard as the ADA Title II Web Rule we covered earlier. This rule applies to any organization that receives HHS funding, which includes hospitals, clinics, health plans, and health systems that participate in Medicare, Medicaid, or any other HHS-administered program.
Critically, the requirement extends to digital tools provided through third-party vendors. If a covered entity contracts with a software company to run its patient portal, that portal must meet the standard. The covered entity retains legal responsibility regardless of where the failure originates.
BURG’s Perspective | What This Means for You
This rule is distinct from the ADA Title II Web Rule, which applies to government entities. Section 504 applies to private healthcare organizations. A hospital that accepts Medicare is covered. A health plan that participates in Medicaid is covered. A clinic that receives any HHS grant is covered. Noncompliance carries the same consequences as other Section 504 violations: loss of federal funding, OCR enforcement, and private litigation.
Current Status
The rule is in effect. The May 11, 2026, deadline for larger organizations is weeks away.
7. FDA Clinical Trial Guidance: Enrollment Practices and Language Access
What Happened
On December 15, 2025, the FDA published updated guidance on Enhancing Participation in Clinical Trials, covering eligibility criteria, enrollment practices, and trial design for drug and biologics applications. The guidance finalizes and replaces the FDA’s 2020 document and reflects the agency’s current thinking on how sponsors should design trials that produce data applicable to the actual patient populations who will use approved therapies.
What the Law Says
FDA guidance documents are recommendations, not binding regulations. That said, the FDA uses guidance documents in its review of applications, and sponsors who consistently deviate from them take on regulatory risk.
On language access specifically, the guidance recommends that sponsors provide trial resources and documents in multiple languages, as well as multilingual staff or interpreters, to encourage participation and retention among LEP individuals. It also recommends community outreach in locations accessible to underrepresented populations, and flexibility in trial design to reduce participation burdens that disproportionately affect non-English-speaking communities.
BURG’s Perspective | What This Means for You
Informed consent forms, patient-reported outcome instruments, recruitment materials, and participant communications all need to work in the languages of the populations being enrolled. IRBs review these materials and can delay first-patient-in dates when language access plans are inadequate. For sponsors running global trials, the documentation and linguistic validation requirements compound quickly across multiple languages and regulatory jurisdictions.
Current Status
The guidance is in effect as of December 2025. It applies to clinical investigations of human drugs and biological products regulated as drugs. Sponsors preparing NDAs and BLAs should review their enrollment practices and participant-facing materials against these recommendations.
8. Joint Commission: New Accreditation Framework for Hospitals
What Happened
On January 1, 2026, the Joint Commission replaced its National Patient Safety Goals with a new framework called National Performance Goals, covering all accredited hospitals and critical access hospitals. No new requirements were added. What changed is how existing requirements are organized and measured, with the new framework moving away from procedural checklists and toward documented outcomes.
What the Standards Require
Two of these goals have direct implications for language access. Goal 4 requires hospitals to show that all patient groups are receiving comparable care. Where they are not, hospitals must produce a written action plan addressing the disparity. Goal 7 requires that patients receive information about their care in a language they understand, with qualified interpreters for informed consent, discharge instructions, and other high-stakes clinical conversations.
BURG’s Perspective | What This Means for You
Accredited hospitals have always been required to provide language access. What changed is what the Joint Commission looks for during accreditation reviews. Having a contracted interpreting service used to be sufficient. Now hospitals need to show, through actual outcome data, that all patient groups, including LEP patients and patients with disabilities, receive care comparable to that provided to English-speaking patients. Access and outcomes are not the same thing, and the Joint Commission is now measuring both.
Current Status
The National Performance Goals are in effect as of January 1, 2026.
9. NPG.07.01.01 | Joint Commission National Performance Goal (January 2026)
What Happened
Effective January 1, 2026, the Joint Commission’s National Performance Goals framework introduced NPG.07.01.01, which requires accredited hospitals to respect each patient’s right to receive information in a manner the patient understands. The goal is active for all accredited hospitals and critical access hospitals.
What the Standard Requires
NPG.07.01.01 requires hospitals and critical access hospitals to respect each patient’s right to receive information in a manner the patient understands. The three Elements of Performance require hospitals to respect the patient’s right to and need for effective communication, provide interpreting and translation services as necessary (with options including bilingual staff, contract interpreters, and in-person, video, or telephone services), and communicate with patients who have vision, speech, hearing, or cognitive impairments in ways that meet their specific needs. The Joint Commission’s published materials confirm that no new requirements were introduced with the NPG transition; these are existing requirements that have been reorganized and elevated in the accreditation framework.
BURG’s Perspective | What This Means for You
NPG.07.01.01 is active now, and the 2026 accreditation survey cycle is underway. The shift from National Patient Safety Goals to National Performance Goals changed how these requirements are organized and weighted within the accreditation process. A contracted language services provider satisfies EP 2 only if it is actually deployed appropriately for the patient population and clinical context. Hospitals that have not assessed whether their current language access program addresses all three Elements of Performance, including disability-related communication needs under EP 3, carry a compliance gap that a language services contract alone does not close.
Current Status
NPG.07.01.01 is in effect as of January 1, 2026, for all accredited hospitals and critical access hospitals, and applies in surveys conducted under the 2026 standards. The Joint Commission has published a series of NPG implementation briefs to support accredited organizations.
10. Language Access for All Act: Proposed Federal Legislation
What Happened
On January 22, 2026, Representatives Grace Meng, Judy Chu, Dan Goldman, and Juan Vargas introduced the Language Access for All Act in the House of Representatives. The bill was referred to the House Committee on Oversight and Government Reform, where it currently remains.
What the Bill Proposes
The legislation is a direct response to Executive Order 14224, which revoked much of the country’s federal language policy. This bill would make language access a permanent federal requirement that future administrations cannot revoke by executive order. Key provisions would require every federal agency to develop and maintain a language access plan, require qualified interpreters for critical communications, and establish a formal complaint process through the DOJ. Noncompliance would be treated as discrimination under Title VI.
Current Status
The bill has not passed and currently remains in committee. The bill is important because executive orders can be revoked by the next administration, as this one was. A statute cannot. If this bill passes, federal language access requirements become permanent law, rather than policy that changes with each administration.
Legal Developments
1. Bayhealth Medical Center (February 2026)
What Happened
On February 4, 2026, the HHS Office for Civil Rights (OCR) reached a voluntary resolution agreement with Bayhealth Medical Center, a Delaware health system, following a complaint from a Deaf patient who uses American Sign Language. The patient alleged that Bayhealth failed to provide a qualified interpreter during his three-day hospitalization. The OCR investigated under Section 504 of the Rehabilitation Act and Section 1557 of the Affordable Care Act.
What the Agreement Required
Bayhealth agreed to modify its policies and procedures for effective communication with patients with disabilities, train all personnel who interact with patients, report any grievances related to auxiliary aids or services to the OCR, and submit compliance reports at six-month intervals. The OCR will monitor Bayhealth’s compliance for two years.
BURG’s Perspective | What This Means for You
Section 504 and Section 1557 require covered health systems to ensure that communication with patients who have disabilities is as effective as communication with anyone else. One complaint from one patient triggered system-wide corrective action and two years of federal monitoring. None of this is new law. What this Bayhealth agreement does give us is a detailed picture of what the OCR expects when a health system has not met these obligations.
2. Alameda County Sheriff’s Office (September 2024)
What Happened
In September 2024, the Department of Justice reached a resolution agreement with the Alameda County Sheriff’s Office in California, resolving a Title VI inquiry into whether the department was providing adequate language services to LEP residents. The agreement was part of the DOJ’s Law Enforcement Language Access Initiative (LELAI), a Biden-era effort to systematically improve language access across state and local law enforcement agencies nationwide.
What the Settlement Required
The Sheriff’s Office agreed to establish a formal language access directive, designate a dedicated LEP Coordinator, provide staff training on language assistance, implement quality controls for accurate language services, and submit to a period of DOJ monitoring.
BURG’s Perspective | What This Means for You
Title VI applies to any organization that receives federal funding, not just law enforcement. If your organization accepts Medicare, Medicaid, federal grants, or government contracts, you operate under the same obligation that produced this agreement.
Having a language services provider is not the same as having a language access program. This agreement is a public record of what federal investigators require: written policies, a designated coordinator, trained staff, and documented quality controls.
3. Freeport Police Department (December 2024)
What Happened
On December 19, 2024, the Department of Justice entered into a Voluntary Technical Assistance Agreement with the Freeport, New York Police Department. This one was different from the Alameda agreement in that Freeport was not under investigation. The department came to the DOJ on its own, making it the first proactive agreement of its kind under the program.
What the Agreement Required
Over two years, the DOJ agreed to help Freeport build a complete program covering written policy, a dedicated coordinator, mandatory staff training, and interpretation protocols for different types of police encounters.
BURG’s Perspective | What This Means for You
Freeport was the first organization to approach the DOJ voluntarily under LELAI to build a language access program, setting a precedent that any organization receiving federal funding can now follow.
4. MMG Fusion (March 2026)
What Happened
On March 5, 2026, the HHS Office for Civil Rights announced a settlement with MMG Fusion, a Maryland software company that provides marketing tools to dental practices. In December 2020, an unauthorized actor accessed the protected health information of approximately 15 million individuals through MMG’s systems and posted it to the dark web. MMG did not notify the dental practices it served within the required 60-day window. The OCR opened its investigation in 2023 after receiving a complaint about the unreported breach.
What the Settlement Required
MMG agreed to pay $10,000 and implement a corrective action plan that the OCR will monitor for three years. The plan requires MMG to conduct a proper security risk analysis, develop a risk management plan, and train its workforce on HIPAA requirements. The OCR noted it considered MMG’s financial condition in setting the penalty.
BURG’s Perspective | What This Means for You
MMG processed protected health information on behalf of covered entities without conducting a basic security risk analysis. Fifteen million patient records ended up on the dark web and MMG said nothing for three years. The certifications and security requirements your organization asks of its vendors exist for exactly this reason.
About the BURG Brief
The BURG Brief is published quarterly by BURG Translations. Each issue tracks regulatory changes, enforcement actions, and legal developments affecting language access across healthcare, life sciences, manufacturing, and legal services.
The next issue will cover developments in Q2 2026. If a regulation or enforcement action covered in this issue is directly relevant to your organization’s current compliance priorities, contact your BURG account team.
The BURG Brief is published for informational purposes only and does not constitute legal advice. It should not be relied upon as a substitute for consultation with qualified legal counsel. Regulatory obligations vary by organization, jurisdiction, and applicable law. Contact your legal team to assess how the developments covered here apply to your specific situation.
