The availability of language services for patients with limited English proficiency has become a standard of care in the United States. Finding the resources to pay for lan- guage programs is challenging for providers, payers, and policymakers. There is no federal payment policy and states are developing policies using different methodologies for deter - mining costs and reimbursement rates. This paper establishes a conceptual framework that identifies program costs, can be used across health care entities, and can be understood by administrators, researchers, and policymakers to guide research and analysis and establish a common ground for informed strategic discussion of payment and reimbursement policy. Using case study methods, a framework was established to identify costs and included deter- mining the perspective of the cost analysis as well as distinguishing between the financial accounting costs (direct, indirect, and overheard costs) and the economic opportunity and subsequent utilization costs.