Compliance

Non-Discrimination Policy

 As a recipient of Federal financial assistance, Presbyterian Homes does not exclude, deny benefits to, or otherwise discriminate against any person on the basis of race, color, national origin, disability, or age in admission to, participation in, or receipt of the services and benefits under any of its programs and activities, whether carried out by Presbyterian Homes directly or through a contractor or any other entity with which Presbyterian Homes arranges to carry out its programs and activities.

This statement is in accordance with the provisions of Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and Regulations of the U.S. Department of Health and Human Services issued pursuant to these statutes at Title 45 Code of Federal Regulations Parts 80, 84, and 91.

 

In case of questions, please contact the Section 504 Coordinator at your campus, or the Chief Compliance Officer, who can be reached at:

 

Lake Forest Place                                        (847) 604-6701

Westminster Place                                       (847) 866-1650

The Moorings of Arlington Heights             (847) 956-4500

Corporate                                                     (847) 733-2324

TDD or State Relay Number:                       (800) 526-0844 (TTY only)

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Language Assistance Services for Limited English Proficiency

Presbyterian Homes adheres to Illinois Administrative Code for Long Term Care Facilities.  Per IL Administrative Code Title 77: Public Health Part 940 Language Assistance Services Code, a health facility shall ensure access to health care information and services for limited-English-speaking or non-English speaking residents or patients or deaf residents or patients.

For the purposes of this policy, a limited English speaking person is one who is unable to speak, read, write or understand the English language at a level that permits effective interaction with health center staff. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the person being served, and patients/clients and their families will be informed of the availability of such assistance free of charge.

 

PROCEDURE

Facility: 

  1. Posts at the entrance to the facility a notice to advise patients or residents and families of the availability of interpreters, procedure for obtaining an interpreter, and telephone number to call to file a complaint about interpreter service problems. (See Attachment ).

Director of Admissions:

  1. Prior to admission, asks the hospital referral source if the patient will require language assistance services.
  1. Verifies whether those services are available to the patient through family/friends/ or an established interpreter or if the facility needs to provide services.
  1. Notifies staff that a limited- or non-English speaking resident or severely hearing impaired resident will be admitted to the Health Center. 

Some limited or non-English speaking persons may prefer or request to use a family member or friend as an interpreter.  However, family members or friends of the limited or non-English speaking person will not be used as interpreters unless specifically requested by that individual and after the limited or non-English speaking person has understood that an offer of an interpreter at no charge to the person has been made by the facility.  Such an offer and the response will be documented in the person’s file.  If the limited or non-English speaking person chooses to use a family member or friend as an interpreter, issues of competency of interpretation, confidentiality, privacy, and conflict of interest will be considered.  If the family member or friend is not competent or appropriate for any of these reasons, competent interpreter services will be provided to the limited or non-English speaking person.

 

Children and other clients/patients/residents will not be used to interpret, in order to ensure confidentiality of information and accurate communication. 

Nursing:

  1. If possible, assigns caregiver(s) to limited or non- English speaking resident who speaks the resident’s dominant language.
  1. If an interpreter is not immediately available and/or until services are available, utilizes one of the following on- line products to interpret immediate questions or needs:
  • Google WordMonkey Translator (translates words or phrases from English into one of 43 different languages)
  • apples4the teacher.com/translate.html (accepts 30 characters & translates into ASL hand signs)
  • widgetbox.com/widget/asl-fingerspelling- translator
  1. Provides TDD/TTY telephone for hearing impaired resident if requested.

 

Social Worker :

  1. Identifies and records the resident’s primary language and dialect in the medical record.
  1. Arranges for interpreter services for resident as needed.
  1. Prepares and maintains a list of interpreters who have been identified as proficient in sign language according to the Interpreter for the Deaf Licensure Act of 2007.
  1. Maintains a list of languages of the population of the geographical area served by the facility.

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 Grievance Procedure 

A grievance is a significant complaint or concern arising from a denial of an applicant’s admission to one of Presbyterian Homes’ Health Care Centers. To assure fair treatment for all individuals denied admission to a Health Care Center, a grievance procedure is followed. This is based on the following:

Section 504 of the Rehabilitation Act prohibits discrimination based on handicap. In accordance with Section 504 Regulation, any program participant (patient, resident, etc.), participant representative, prospective participant who has reason to believe that he/she has been mistreated, denied services or discriminated against in any aspect of services or because of handicap may file a grievance. In order to implement this policy, this agency/facility has adopted an internal grievance procedure providing for prompt and equitable resolution of complaints alleging any action prohibited by the U.S. Department of Health and Human Services regulation (45 CFR Part 84) implementing Section 504 of the Rehabilitation Act of 1973 as amended (29 U.S.C. 794) Section 504 states, in part, that “no otherwise qualified handicapped individual…shall, solely by reasons of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance…” The law and regulations may be examined in the offices of the Administrators of Health Services at Westminster Place, Lake Forest Place, or The Moorings of Arlington Heights, all of whom have been designated to coordinate the efforts of Presbyterian Homes to comply with the regulations. 

PROCEDURE

Grievant 

  1. Submits a grievance in writing, that contains the name and address of the person filing it, and briefly describes the action alleged to be prohibited by the regulations.
  1. Files a grievance in the office of the Section 504 Coordinator of the Health Care Center within 30 days after the person filing the grievance becomes aware of the action alleged to be prohibited by the regulation. This time frame may be waived by the Coordinator if extenuating circumstances exist that justify an extension.

The Section 504 Coordinator is each campus’ Health Care Administrator, and the corporate office’s Chief Compliance Officer, who can be reached at:

 

Lake Forest Place                                             (847) 604-6701

Westminster Place                                            (847) 866-1650

The Moorings of Arlington Heights                  (847) 956-4500

Corporate                                                          (847) 733-2324

Coordinator or designee

  1. Conducts such investigation of a grievance as may be appropriate to determine its validity. These rules require thorough investigations, affording all interested persons and their representatives, if any, an opportunity to submit evidence relevant to the grievance. Under section 504 of the Rehabilitation Act, 45 CFR 84.7(b), the agency/ facility need not process complaints from applicants for employment.
  1. Issues a written decision determining the validity of the grievance no later than 10 days after its filing.
  1. If the grievance has not been resolved at this point, forwards it to the Campus Executive Director, who shall have an additional 10 days to resolve the grievance.

Vice President /Campus Executive Director

  1. Notifies the grievant in writing of the decision and lists the evidence on which the decision is based. 

Grievant

  1. The availability and use of this grievance procedure does not prevent a person from filing a complaint of discrimination on the basis of disability with the U.S. Department of Health and Human Services, Office for Civil Rights. 

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Section 504 – Notice of Program Accessibility

Presbyterian Homes and all of its programs and activities are accessible to and useable by disabled persons, including persons who are deaf, hard of hearing, or blind, or who have other sensory impairments. Access features include:

  • Accessible parking designated specifically for disabled persons.
  • Access via ramps between parking areas and buildings.
  • Level access into first floor level with elevator access to all other floors.
  • Fully accessible offices, meeting rooms, bathrooms, public waiting areas, cafeteria, patient treatment areas, including examining rooms and resident rooms.
  • A full range of assistive and communication aids is made available to persons who are deaf, hard of hearing, or blind, or with other sensory impairments. There is no additional charge for such aids. Some of these aids include:
    • Qualified sign language interpreters for persons who are deaf or hard of hearing.
    • Readers and taped material for the blind and large print materials for the visually impaired.
    • Flash cards, alphabet boards and other communication boards.
    • Assistive devices for persons with impaired manual skills.

 

If you require any of the aids listed above, please make the admission staff aware of our need for assistance.

The regulation implementing Section 504 requires that an agency/facility "…adopt and implement procedures to ensure that interested persons, including persons with impaired vision or hearing, can obtain information as to the existence and location of services, activities, and facilities that are accessible to and usable by disabled persons." (45 C.F.R. §84.22(f))

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