For healthcare payers offering Medicare Advantage and Dual Special Needs Plans (D-SNPs), the translation of member-facing materials is a costly, complex and high-stakes process. Translation requirements place an enormous burden on payers and, yet, it is critical for a positive member experience and accessibility in the U.S., where nearly 68 million people speak a language other than English at home.
The Centers for Medicare & Medicaid Services (CMS) mandates that materials such as Annual Notices of Change (ANOCs), Evidence of Coverage (EOCs) and Summaries of Benefits (SBs) be translated for any population language group comprising 5% or more of a plan’s service area population. The 2024 CMS Final Rule extends this obligation: Once a member from a qualifying language group requests translated materials, the payer must continue providing translated materials on an ongoing basis. D-SNPs must also meet state Medicaid requirements, which can increase translation demands to support more than 20 languages.
Today, most payers rely on traditional translation services performed by humans. These services are slow, expensive and highly dependent on rigid, manual processes. Translations on CMS mandated materials typically begin only after English versions are finalized, creating a compressed timeline that introduces stress, errors and increased costs as deadlines approach. Despite significant financial investment, many health plans find themselves scrambling each year to meet CMS timelines.
This is where AI—specifically generative AI—offers transformative potential. AI can dramatically accelerate the translation process, reduce reliance on overburdened human translators and improve consistency and accuracy. GPT-4 and other large language models have demonstrated tremendous effectiveness with translation. But AI alone is not a silver bullet: Healthcare payers must evaluate AI tools based on how they support compliance, accuracy and security within a highly regulated ecosystem.
Additionally, the sensitive nature of some member communications, particularly those that may include personal health information (PHI), makes data privacy and governance essential. Using standalone AI translation tools that are not integrated into a communications management platform can create security risks and introduce workflow inefficiencies. Manual steps where teams are copying content out of a document generation system and pasting it into AI systems is not only wildly inefficient, but they also increase the potential for data leaks, formatting errors or delays. A tightly integrated solution that embeds AI into secure and structured workflows can mitigate these risks while improving speed and scalability.
What Health Payers Should Demand from AI Translation Solutions
While the market for AI-based content and translation solutions is growing at a rapid pace, not all are built to meet the rigorous demands of Medicare Advantage materials. Due to the complex nature of these documents and communications, health payers should focus on how well AI-powered solutions align with existing workflows, CMS compliance requirements and multilingual engagement strategies.
Here are four critical capabilities to look for:
- Built for Medicare Advantage, Not DIY AI
Avoid technology that expects your team to write and manage their own generative AI prompts; rather, solutions that are designed to support Medicare-specific translations offer prompts that are built in and refined by experts. This ensures more consistent, compliant outputs and removes the guesswork from the translation process.
Also, look for capabilities that include glossaries. Medicare Advantage plans rely on precise, consistent language. Platforms that support controlled glossaries enable payers to enforce uniform translation of critical terms—such as plan types, cost-sharing terms or regulatory phrases—ensuring compliance and clarity across languages.
- Built-in Translation Validation Tools
Translation accuracy matters. Translation itself is only part of the battle; subsequent proofing and quality assurance are a major undertaking. Manual quality reviews of translated ANOCs, EOCs and SBs add a significant burden that can be alleviated by AI-driven validation capabilities that automatically compare the semantic meaning of source and translated content to flag discrepancies. These capabilities should also check that all the correct variables and data-driven content are in the materials and in the right order and flow to help ensure accuracy across languages and require manual reviews for exceptions only.
- Protection of Format Integrity
Many healthcare documents have formatting requirements defined by CMS. If these elements are put at risk and reset every time a translation occurs, it is costly and time-consuming to rework those documents. Ideally, teams should preserve these elements during AI translation, avoiding costly rework and reducing the risk of formatting errors.
- Configurable Workflows and Full Traceability
Compliance-driven environments demand transparency. It is critical to be able to seamlessly manage the workflow of who is working on a document and when, whether that is a human or AI, and automate related notifications. Just as important, your translation solution should offer audit trails to provide version control and clarity around what changes were made, when and by whom.
By embedding AI within a secure and structured document generation and communications management platform, health payers can scale their translation processes to meet CMS requirements without overburdening internal resources. This approach reduces operational costs, enhances accuracy and accelerates time to delivery—all while ensuring compliance and maintaining the integrity of critical member communications. The right technology allows you to go beyond checking the box on compliance and move toward truly member-centered, multilingual engagement. As member populations become more diverse and regulatory requirements more complex, leveraging AI effectively can be a strategic differentiator for payers committed to service, accessibility and operational excellence.
About Patrick Kehoe
Patrick Kehoe is Executive Vice President of Product Management, driving product strategy in collaboration with the product development team at Messagepoint, a provider of customer communications management software. Kehoe brings to the company more than 25 years of experience delivering business solutions for document processing, customer communications and content management.
