Jose Guitron v. Santa Fe Extruders, ADJ163338, 76 Cal. Comp.Cases 228
(Appeals Board En Banc 3/17/11) provides that the employer is required to
provide reasonably required interpreter services during medical treatment
appointments for an injured worker who is unable to speak, understand, or
communicate in English.  Interpreter lien claimants have the burden of
proving, among other things, that the services it provided were reasonably
required, that the services were actually provided, that the interpreter was
qualified to provide the services, and that the fees charged were
reasonable.