CMS’s 7-Day Rule Is Coming. If You Translate Member Notices, You’re on the Clock.
Starting January 1, 2026, the Centers for Medicare & Medicaid Services (CMS) will reduce the timeline for pre-service standard referral decisions from 14 days to 7 calendar days. That change, along with existing federal notice requirements, means translated member notifications are about to move from important to critical path.
For plans that handle high volumes or multiple threshold languages, this shift compresses the available window for translation, formatting, QA, and delivery. If you don’t have automation, governance, and real-time visibility in place, hitting the new 7-day mark could be tough.
Here’s what’s changing, why it matters, and how to prepare.
What CMS Is Changing (Effective January 1, 2026)
A combination of rules is driving the change:
- The CMS Interoperability and Prior Authorization Final Rule cuts the decision-making window for Medicare pre-service standard referrals from 14 calendar days to 7.
- Standard CMS notification requirements (under 42 CFR 438.210) require plans to notify members by the deadline.
- Translation obligations under existing CMS and contractual language access rules mean many of those notices must be translated before they are delivered.
The result? Translations are now firmly inside the 7-day window. If you need to translate the notice, it’s no longer a back-end task. It’s on the critical path.
What This Means Operationally
For utilization management and member services teams, the impact is real:
- Shorter clock. Member notices must be sent by day 7, including any required translations.
- Translation in scope. If your contracts require translated member letters, those translations must be completed, QA’d, and delivered within the deadline.
- Volume risk. The more referrals you handle, or the more languages you serve, the more complex and time-sensitive this becomes.
Even if you’re not feeling the pressure yet, plans with growing language access requirements or tighter SLAs will need to adapt quickly.
What We’re Hearing from Clients
Some teams have already flagged the change and confirmed their readiness. If your notice volumes are modest, and you’re seeing 1–2 day translation turnarounds, you may already be covered.
But for plans with higher daily volumes or multilingual member bases, the risk is harder to ignore. Manual steps, vendor delays, or unclear accountability can easily add up to missed deadlines.
The organizations that act early will avoid the scramble and build workflows that scale.
How BIG Helps Teams Stay Ahead
BIG offers two purpose-built solutions to help plans meet the 7-day rule reliably, even at scale.
LanguageExpress™
For high-volume, templated notices. A fully automated workflow that brings together:
- Automated ingest of notice templates and member-specific data
- Client-trained MT, translation memories, and glossaries
- Automated QA plus targeted human QC
- Print-ready or EHR-formatted output
- Built-in audit trail inside LanguageVault™
LanguageExpress™ can turn around most translated notices within 1–2 days, often faster, giving teams enough buffer to meet the full 7-day window with time to spare.
LanguageNow™
For near-real-time, member-specific letters. When notices require custom content or same-day delivery, LanguageNow™ provides:
- Instant access to client-trained translation engines
- Secure translation workflows inside LanguageVault™
- Near-real-time output for urgent cases
- Optional human review based on your internal policies
What to Ask Yourself
If you’re not sure whether these changes apply to you, here are a few quick prompts:
- Which member notices tied to UM decisions require translation under your contracts?
- What’s your average daily referral volume and language mix?
- Where do you need same-day vs next-day turnarounds?
- What documentation do auditors expect? Export logs, timestamps, delivery proof?
If the answers aren’t clear or the turnaround times are tight, now is the time to reassess your workflow.
The Bottom Line
Translation is no longer a downstream task. For many plans, it’s now directly tied to regulatory timeliness.
BIG’s LanguageExpress™ and LanguageNow™ solutions are built to support this shift, with automation, client-trained translation, and built-in QA that keeps your notices compliant, traceable, and on time.
Want to walk through your workflow together? Contact us to find out how we can help you stay ahead of CMS’s 2026 deadline.
