It is the policy of Detroit Behavioral Institute (DBI) – Capstone Academy to ensure that the organization embraces the principles of equal access and non-discriminatory practices in service delivery. DBI shall effectively and efficiently address the treatment and psychosocial needs of residents and families with diverse values, beliefs, and sexual orientations, in addition to backgrounds that vary by race, ethnicity, religion, abilities, and language. This includes ensuring that residents with Sensory Impairments and Limited English Proficiency (LEP) are given, accurate and timely assistance to obtain effective and meaningful services. All individuals seeking services will be given adequate information to be able to understand their rights and the services available. This policy also establishes guidelines for the provision of interpreters for residents with hearing impairment, and assures that speech, language, and hearing services are available.
The purpose of this policy is to provide a set of principles that enable the organization’s personnel to work effectively with culturally diverse individuals and underserved communities.
All Detroit Behavioral Institute – Capstone Academy Staff
Cultural Competence: Cultural competence in health care describes the ability of systems to provide care to consumers with diverse values, beliefs and behaviors, including tailoring delivery to meet social and cultural needs. It is a set of behaviors, attitudes and policies that come together in a system, agency, or among professionals and enables that system, agency, or those professionals to work effectively in cross–cultural situations and achieve preferred outcomes. Cultural competence is a developmental process that evolves over an extended period of time. Both individuals and organizations are at various levels of awareness, knowledge and skills along the cultural competence continuum.
Individuals with Hearing Impairment – a person whose hearing is partially or totally impaired up to and including complete deafness where hearing, with or without amplifications, is so impaired that the primary means of receiving spoken language is through visual or other sensory input including, but not limited to, lip reading, sign language, finger spelling or reading, gestures or tactile signs.
Foreign Language Interpreters/Translators – Individuals who have a bachelor’s degree from an accredited institution, preferably in languages or linguistics and possess at least one year of specialized experience in interpreting, translating or other work requiring the use of English and the foreign language from (to) which the interpretation/translation is being provided.
Limited English Proficiency (LEP) – a limited ability to speak, read, write, or understand the English language at a level that permits him or her to interact effectively with health and social service agencies and providers.
Sign Language Interpreters – an individual who has a bachelor’s degree from an accredited institution, preferably in Humanities or related fields and certified by the Registry of Interpreters for the Deaf (RID) assessed by the National Association for the Deaf (NAD) or qualified as per the state quality assurance (QA) Levels Descriptions as a QA Level III and possesses at least one year of experience working with deaf and hearing impaired individuals.
Translator – an individual or device that translates, in writing or speech, from one language into another. (Encarta® World English Dictionary [North American Edition] © & (P) 2006)
Individual with Visual Impairment –an individual whose eyesight cannot be corrected to a “normal
level”, (Center for Disease Control Definition) including the functional limitation of the eye or eyes or the vision system that leads to any of the following:
1. Individuals Loss of visual acuity and inability of the person to see objects as clearly as a healthy person
2. Loss of visual field meaning inability of an individual to see as wide an area as the average person without moving the eyes or turning the head.
3. Photophobia – inability to look at light
4. Diplopia – double vision
5. Visual distortion or distortion of images
6. Visual perceptual difficulties or difficulties of perception
7. Any combination of the above features
8. Blindness – as defined as a visual acuity worse than 20/400 with the best possible correction, or a visual field of 10 degrees or less.
9. Legal blindness in the US means visual acuity of 20/200 or worse with the best possible correction or a visual field of 20 degrees or less.
Individual with Sensory Impairment – A person who has an inability to accurately interpret an outside source or stimuli, whether it be visual, auditory, verbal, through sense of touch, sense of taste or the ability to feel pain.
a. DBI shall ensure that staff, at all levels and across all disciplines, receive ongoing education and training in culturally appropriate service delivery to enhance staff knowledge and skills in the provision of services and supports to diverse groups. Requirements of staff education and training include, but are not limited to the following:
i. The organization shall monitor culturally sensitive care learning needs and incorporate cultural competency into the organizational plan, which at a minimum should include:
1. Federal, State, county and local laws and regulations that relate to culturally diverse populations and nondiscrimination practices.
2. Prevalence of current and projected cultural/linguistic groups within the facility
3. The socioeconomic and environmental risk factors that contribute to the major problems of culturally, ethnically, linguistically and racially diverse populations served.
4. Impact of social and cultural/linguistic factors on mental health beliefs, mental health seeking behavior, health practices, communication and recovery.
5. Self-awareness in cross-cultural situations in the workplace with consumers, families, community groups, contractors, co-workers, supervisors, managers, etc.
6. Natural sources of supports and cultural brokers in the community.
7. References to other related training modules that may be scheduled and available through the Virtual Center of Excellence (VCE) :
a. Limited English Proficiency (LEP)
b. Culture of Gentleness
c. Improving Integrated Co-Occurring Disorders Treatment: Individualized, Person-Centered Service Plans and Documentation
d. Collaboration and Personal Success
e. Cultural Competency: Working With Lesbian, Gay, Bi-attractional, Transgendered, and Questioning (LGBTQ) Youth
b. DBI shall seek to utilize stakeholders (i.e., consumers, families, advocates, community groups, schools of higher learning, etc.) from diverse communities for evaluation of program activities.
c. DBI shall keep accurate records of staff cultural competence training.
d. DBI shall provide communication aids (at no cost to the person being served) to limited English Proficient (LEP) persons, including current and prospective residents, family members and interested persons to ensure them a meaningful opportunity to apply for, receive or participate in, or benefit from the services offered.
e. DBI shall offer and provide language assistance services, for persons with Limited English Proficiency, at all points of contact, and in a timely manner during all hours of operation.
f. DBI will reasonably ensure that information about services, consent forms, waivers or rights, financial obligations, etc. is communicated to LEP persons in a language which they understand and will provide for an effective exchange of information between staff/employees and residents/guardians and or families while services are being provided.
g. DBI shall take such steps as are necessary to ensure that qualified person with disabilities, including
those with impaired sensory or speaking skills, limited English proficiency, developmental disabilities or visual impairments receive effective notice concerning benefits or services or written material concerning waivers of rights or consent to treatment. All aids needed to provide this notice will be provided without cost to the person being served.
h. DBI shall not rely on resident or family interpreters, resident readers, or other types of resident assistants except in limited circumstances where an extended delay in obtaining an effective interpreter could compromise the resident’s safety, the performance of first-response duties, or the investigation of a resident’s allegations of sexual abuse or harassment.(PREA 115.316)
i. DBI shall take reasonable steps to ensure meaningful access to all aspects of the its efforts to prevent, detect, and respond to sexual abuse and sexual harassment to residents who are limited English proficient, including steps to provide interpreters who can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary. (PREA 115.316)
j. DBI shall ensure that Individual Treatment Plans have evidence of cultural/LEP issues and values.
k. DBI shall ensure that culturally and linguistically competent literature is made available where possible. For material that is unavailable, oral interpretation service shall be provided.
l. For individuals with hearing impairments and individuals who use sign language as their primary means of communication, DBI shall ensure that qualified sign language and/or oral interpreters shall be provided to residents receiving services if needed.
m. DBI shall take appropriate steps to ensure that residents with disabilities (including residents with hearing impairment, visual impairment, sensory impairment, or those who have intellectual, psychiatric, or speech disabilities), have an equal opportunity to participate in or benefit from all aspects of its efforts to prevent, detect, and respond to sexual abuse and sexual harassment. Such steps shall include, when necessary, to ensure effective communication with residents who are deaf or hard of hearing, providing access to interpreters who can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary. In addition, the agency shall ensure that written materials are provided in formats or through methods that ensure effective communication with residents with disabilities, including residents who have intellectual disabilities and limited reading. (PREA 115.316)
n. For persons with visual impairments, DBI shall ensure that reader/staff will communicate the content of written materials concerning benefits, services, waivers of rights and consent to treatment forms by reading them aloud to visually impaired persons.
o. For persons with Speech impairments: writing materials and computers are available to facilitate communication concerning benefits, services, waivers of rights and consent to treatment forms.
p. DBI shall ensure that speech, language, and hearing services are available to clients as identified in their Treatment Plans.
q. DBI shall ensure that the physical environment(s) reflect visual images that reflect cultural groups / diversity.
r. DBI shall make available easily understood materials and post signage in the languages of commonly encountered cultural groups and/or cultural groups represented in the service area.
s. Monitor to ensure that individual consumer’s race, ethnicity, spoken and written languages are collected in resident files so accurate data may be obtained.
a. DBI shall ensure that interested persons, including persons with impaired vision or hearing, can obtain information as to the existence and location of its services, activities, and facilities that are accessible to and usable by disabled persons.
b. DBI Access features shall include:
i. Parking designated specifically for disabled persons
ii. Ramps to assist with entrance to the facility.
iii. Level access into first floor level with elevator access to all other floors.
iv. Fully accessible meeting rooms, public waiting areas, cafeteria, and patient treatment areas.
v. A full range of assistive and communication aids available upon request to persons with impaired hearing, vision, speech, or manual skills, without additional charge for such aids.
3. Notice of Services
a. DBI shall ensure that interested persons, including those with impaired hearing or vision, can obtain information about DBI’s facilities which are accessible and usable by disabled persons by….
b. DBI shall notify disabled persons, including those with sensory or speech impairments, of any general notices of their services and of written materials concerning waivers of rights or consent to treatment, (e.g. information releases, financial agreements, insurance assignments, informed consent for treatment)
c. DBI shall include its non-discrimination notice in publications of general information regarding its programs and program manual.
VI. QUALITY ASSURANCE:
The Detroit Behavioral Institute – Capstone Academy Quality Improvement Committee shall monitor adherence to the policy and procedures as one element of its overall quality assurance processes. The Detroit Behavioral Institute – Capstone Academy Policy and Procedure Manual is reviewed annually by the Detroit Behavioral Institute – Capstone Academy Quality Improvement Committee and is approved annually by the Board of Managers.
VII. COMPLIANCE WITH ALL APPLICABLE LAWS:
The Detroit Behavioral Institute – Capstone Academy is bound by all applicable federal, state and county laws, standards, provisions, rules, regulations, policies, and guidelines. These laws, standards, provisions, rules, regulations, policies, and guidelines include but not limited to all applicable Council On Accreditation (COA) Standards, State of Michigan Department of Human Service Bureau of Children & Adult Licensing Provisions, Juvenile Justice Service Standards and all United States Federal Regulations.
Title VI of Civil Rights Act of 1964, Section 504 of Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and Regulations of the US Department of Health and Human Services issued pursuant to the Acts, Title 45 Code of Federal Regulations part 80,84, and 91.