Workers’ Compensation · Primary-source case analysis

Guitron: Interpreter Services May Be Required During Medical Treatment

By Aneeta Mishra and Timothy Chan

Published September 13, 2026

Guitron v. Santa Fe Extruders recognizes interpreter services as part of medical treatment while defining the evidence an interpreter lien claimant must present to obtain payment.

Communication was necessary to obtain treatment

The injured worker spoke Spanish and needed interpretation during medical appointments. The dispute concerned whether the employer’s medical-treatment duty included interpretation and what the interpreter had to prove on its lien.

Reasonably required interpretation is part of treatment

The Board held that an employer must provide interpreter services when they are reasonably required to enable an injured employee to communicate during medical treatment. The obligation follows the treatment need; it is not limited to formal hearings or medical-legal examinations.

The lien claimant must prove the services

An interpreter seeking payment bears the burden of establishing that the services were reasonably required, actually provided, performed by a qualified interpreter, and billed at a reasonable rate. A generalized invoice does not eliminate the need for supporting proof.

The case was returned for factfinding

The en banc decision established the legal standard and returned the matter for further proceedings on the evidentiary record. It did not declare every requested interpreter service compensable or fix a universal rate.

Key takeaways

• Document why language assistance was required for each appointment.
• Preserve attendance, service, qualification, and billing records.
• Connect the interpretation to authorized or compensable treatment.
• Evaluate the reasonable rate on the developed record.