CMS Secret Shopper 2026: The Biggest Language Access Lesson Nobody Talks About

Every year around this time, health plans begin preparing for the next enrollment cycle. Teams review member materials, evaluate vendors, revisit compliance processes, and prepare for another round of CMS scrutiny to support members with limited English proficiency (LEP).

Most of the conversation focuses on the same question:

"Do we have language access coverage?"

After reviewing thousands of CMS-related interpretation calls throughout the 2026 Secret Shopper season, I think the better question is:

"Do we have language access coverage when it matters most?"

Because the reality is this: CMS doesn't measure your average day. It measures the one moment that goes wrong.

The Good News: Most Plans Are Better Than They Think

Looking across the 2026 season, the overall story is actually pretty positive.

Average Speed to Answer (ASA) remained remarkably consistent, generally sitting between 8 and 10 seconds across all monitored languages. Even as call volumes fluctuated throughout the season, performance remained stable.

For health plans, that's encouraging. It means the industry as a whole has gotten significantly better at providing timely access to over-the-phone interpretation (OPTI) and other language assistance services.

But averages only tell part of the story.

Spanish Isn't the Problem Anymore

If you've worked in healthcare long enough, you probably assumed Spanish would be the biggest challenge. It wasn't. 

Spanish represented roughly two-thirds of all CMS call volume throughout the season. Week after week, it handled hundreds of calls while maintaining strong service levels.

Think about that for a second. The language carrying the overwhelming majority of volume was often the most stable. Why?

Because health plans know Spanish is important. They plan for it. They forecast it. They staff for it.

The operational muscle memory exists.

The Real Risk Lives Somewhere Else

The biggest lesson from this year's CMS data is that compliance risk doesn't typically come from your highest-volume language. It comes from the languages that may only receive a handful of calls each day.

Vietnamese. Tagalog. Mandarin. French. Cantonese.

Individually, these languages represented only a fraction of overall volume. Collectively, they generated many of the operational conversations throughout the season—not because performance was poor, but because it was fragile.

Sometimes, all it took was a lunch break, an unexpected absence, a schedule adherence issue, or one interpreter being unavailable at exactly the wrong time.

Those seemingly minor events could create a significant spike in wait times.

For organizations relying on over-the-phone interpretation, these interval-level staffing gaps can quickly become compliance risks.

CMS Doesn't Grade on Averages

One of the most common mistakes I see is organizations focusing exclusively on weekly or monthly averages.

Members don't experience averages. They experience moments.

If CMS calls at 10:17 AM on a Tuesday and your coverage happens to be thin for a particular language, it doesn't matter that your weekly ASA was 9 seconds. For members with LEP, that single interaction defines their entire experience.

Looking at the 2026 data, most performance issues weren't broad operational failures. They were isolated interval-level gaps.

That's a very different problem to solve.

Language Insights from the Season

Vietnamese: The Most Sensitive Language

If I had to pick one language that consistently demanded attention, it would be Vietnamese.

Volume wasn't necessarily high, but when coverage gaps appeared, performance reacted quickly. Several of the largest wait-time spikes during the season occurred within Vietnamese queues.

Tagalog: Small Volume, Big Risk

Tagalog reinforced something we've seen for years: low volume does not equal low importance.

With fewer calls, there’s less room for error. A single staffing issue can have a much larger impact than it would in a higher-volume language queue.

Mandarin: Consistent Demand Requires Consistent Staffing

Mandarin demand remained relatively steady throughout the season.

The challenge wasn't volume. It was making sure coverage matched demand throughout the day instead of focusing solely on peak hours.

French: The Sneaky One

French may have been the most deceptive language of the year.

Average performance often looked great, yet several weeks produced significant wait-time spikes.

If you're only looking at dashboards, you'd miss the story entirely.

Cantonese: Stable but Not Immune

Cantonese generally performed well, but like the other LOTS languages, isolated staffing gaps could still create outsized impacts.

The lesson remains the same: stability requires intentional planning.

What Health Plans Should Take Away from This

The biggest takeaway from the 2026 CMS Secret Shopper season isn't that plans need more interpreters. It's that plans need more precision. 

Most organizations have solved for access. The next challenge is solving for responsiveness. 

That means understanding demand by language, by hour, by interval, and having the operational flexibility to react before a service issue becomes a compliance issue.

It also means continuously evaluating your language assistance services to ensure consistent performance across every language—not just your highest-volume ones.

Because the organizations that perform best aren't necessarily the ones with the most resources. They're the ones paying attention to the details.

Looking Ahead to 2027

As plans begin preparing for next year's enrollment season, I expect language access to receive even more scrutiny alongside broader accessibility and member experience initiatives. The good news is the industry is moving in the right direction. The better news is that the biggest opportunities are now highly visible. After reviewing this year's data, one conclusion stands above all the others: Spanish drives the volume. LOTS languages drive the risk. And CMS performance isn't won through averages. It's won in the moments members need help most.

Ready for the 2027 CMS Secret Shopper season? Connect with TransPerfect to learn how we can help strengthen your language access strategy and prepare for the moments that matter most.