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Cultural & Linguistic Program Description

MPLD7001

June 2020

Original Date: 02/19/2014Revision Date(s): 02/18/15; 01/20/16; 02/15/17; *02/14/18; 09/12/18; 09/11/19; 06/10/20

*Through 2017, Approval Date reflective of the Quality/Utilization Advisory Committee meeting date. Effective January 2018, Approval Date reflects that of the Physician Advisory Committee’s meeting date.

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Program Purpose

Partnership HealthPlan of California (PHC) is committed to delivering culturally and linguistically appropriate services (CLAS) to all eligible members with limited English proficiency (LEP) or sensory impairment. PHC’s Cultural and Linguistic Services comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. Section 2000d, and 45C.F.R. Part 80) and the Cultural and Linguistic Services requirements in accordance to the contractual agreement with the Department of Health Care Services (DHCS), Department of Managed Health Care (DMHC), and the Centers for Medicare and Medicaid Services (CMS).

The goal of the Cultural and Linguistic Services Program is to ensure that PHC members, expressly members with limited English proficiency (LEP) or sensory impairment, receive equal access to health care services that are culturally and linguistically appropriate. PHC does not discriminate against its members because of race, color, creed, religion, ancestry, marital status, sexual orientation, national origin, age, sex or physical or mental disability.

Program objectives include:

Comply with state and federal guidelines related to caring for LEP and sensory impaired members.

Improve the quality of health care services for all PHC members at medical and non- medical points of contact.

Promote a culturally competent health care and work environment for PHC. Promote CLAS “best practices” for implementation by PHC, its network providers

and subcontractors. Use outcomes, processes and structure measures to monitor and continuously improve

PHC activities aimed at achieving cultural competence and reducing health care disparities.

PHC’s Population Health unit is responsible for developing, implementing and evaluating PHC’s Cultural and Linguistic Program in coordination with Quality, Provider Relations, Member Services, Communications, Compliance, Information Technology, Health Analytics, Regional Leadership, and Administration.

The Quality and Health Analytics team analyze quality improvement data by race, ethnicity and language to identify health disparities and utilization patterns as it relates to Cultural and Linguistic Services.

Provider Relations is responsible for ensuring that provider network composition continuously meets members’ ethnic, cultural and linguistic needs. Language capabilities of clinicians and other provider office staff are identified during the credentialing process and through an annual, self-reported survey of our primary care provider sites to update PHC’s provider directory.Member Services record members’ cultural and linguistic capability upon enrollment using data acquired from DHCS. Members are informed that they have access to free oral interpretation in their language and written materials translated into PHC’s threshold languages or provided in alternative formats. Member Services is responsible for supporting PHC’s Consumer Advisory

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Committee (CAC) in accordance with Title 22, CCR, Section 53876 (c). The CAC meetings are chaired by designated PHC staff. The purpose of the CAC is to provide a link between PHC and the community. CAC advises PHC on the development and implementation of its cultural and linguistic accessibility standards and procedures. The committee responsibilities include advising on cultural competency, educational and operational issues affecting members, including seniors, persons with LEP, and persons with disabilities. The CAC is composed of PHC members and community advocates.

Communications and Compliance are responsible for ensuring that policies and materials for eligible beneficiaries or potential enrollees do not discriminate due to race, color, creed, religion, ancestry, marital status, sexual orientation, national origin, age, sex or physical or mental disability. Regional Leadership provide insight into the unique needs of their member population, and maintain relationships with regional providers, counties, and community leaders to ensure the cultural and linguistic needs of PHC’s membership are addressed equitably.

Administration, along with PHC’s executive oversight, ensures that PHC’s policies and procedures comply with standards and performance requirements for the delivery of culturally and linguistically appropriate health care services. PHC has systems and processes to:

Assess, identify and track linguistic capability of interpreters, bilingual employees and contracted staff in medical and non-medical settings.

Conduct a Population Needs Assessment (PNA) with corresponding actions every year for Medi-Cal in order to:

o Identify member health education and cultural and linguistic needs. Submit PNA report to DHCS as stated in the contract.

o Continuously develop and improve contractually required health education, cultural and linguistic services, and educational materials

o Monitor and evaluate the Cultural and Linguistic Services and the performance of individuals providing linguistics services.

Provide cultural competence, sensitivity, or diversity training for staff, providers or subcontractors at key points of contact.

Linguistic services are provided by PHC to monolingual, non-English speaking or LEP Medi-Cal beneficiaries for population groups as determined by contract. These services include the following:

No cost linguistic services:o Oral interpreters, sign language interpreters or bilingual providers and provider

staff at key points of contact available in all languages spoken by Medi-Cal beneficiaries. Written informing materials (to include notice of action, grievance acknowledgement and resolution letters) fully translated into threshold languages, upon request

o Use of California Relay Services for hearing impaired.

Through the PNA, PHC regularly assesses and documents member cultural and linguistic needs to determine and evaluate the cultural and linguistic appropriateness of its services. Assessments cover language preferences, reported ethnicity, use of interpreters, traditional health beliefs and beliefs about health and health care utilization. Activities include:

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Document reported ethnicity, preferred language, and use of interpreters in PHC’s information system.

Document member requests to change their reported ethnicity or preferred language. Track and analyze face-to-face and telephonic interpreter service usage rates for all

points of contact. Instruct providers to record members’ language needs in the medical record and

document member requests or refusal of language/interpreter services. Utilize the results of Facility Site and Medical Record Review audits to validate provider

compliance with documentation requirements. Utilize the findings and conclusions from the Population Needs Assessment to

continuously develop and improve the cultural and linguistic services program. Gather additional member input through member surveys, focus groups and grievance

analysis.

Core content of the PNA

DHCS – PNA goals: Evaluating beneficiary health risks Identifying member health needs Prioritizing health education and C&L services Prioritizing QI programs and resources.

PNA Identifies: Member health status and behaviors Member health education and C&L needs Community health education and C&L programs and resources Health disparities and gaps in services

PHC continuously assesses the linguistic capabilities of its employees, providers and subcontractors to reduce language barriers, to increase the quality of care LEP members receive, and ensure the plan’s ability to meet members’ ethnic, cultural and linguistic needs. Activities that contribute to the assessment process include:

Employeeso Hire staff that demonstrates appropriate bilingual proficiency at medical and

non- medical points of contact.o Use a contracted vendor to test PHC employee positions that require bilingual

language proficiency.o Maintain human resource records on staff linguistic skills and relevant

training, certification and/or proficiency results.o Maintain the community health resources page on PHC website showing the

services offered in the counties we serve, including the language(s) in which the programs are offered.

Providerso Primary Care Providers (PCP) and Specialists are required to ensure access

to care for members with LEP through the provider’s own multilingual staff or through cultural and linguistic services facilitated by PHC.

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o Identify language proficiency of bilingual primary care providers and office staff through a standard self-assessment tool.

o Reporting provider and office staff language capabilities in the Provider Directory.

Subcontractorso Execute agreements with subcontractors that include compliance with all product

lines of business requirements.o Execute agreements with contracted translators and interpreters that require staff

to be tested for proficiency and experience.

PHC ensures access to interpreter services for all LEP and sensory impaired members through several mechanisms:

Inform new enrollees of available linguistic services during a welcome call and in welcome packets.

Provide a Quick Reference Guide to demonstrate to providers how to access our interpreter services.

Provide an interpreter for scheduled appointments when requested by the provider or member.

Ensure that members can use face-to-face language and sign language interpreters with advance notice.

Make 24-hour access to telephonic interpreter services available for all medical and non- medical points of contact as defined in the contract or regulations.

Monitor the interpreter request process to avoid unreasonable or unnecessary delays when the service is requested by the member or provider.

Encourage the use of qualified interpreters rather than family members or friends. (The member may choose an alternative interpreter at his/her cost after being informed of the no cost service.)

Discouraging the use of minors as interpreters except in extraordinary circumstances. Maintain records in the Member Services department of the languages available from the

interpreter services. Translate all written member informing materials into PHC’s threshold languages and

make materials available in alternative formats as requested, such as Braille, large print, CD, or audio cassette.

Maintain records in the Member Services department of translated member informing materials.

Ensure members are made aware that they have the right to file a complaint or grievance if their linguistic needs are not met.

PHC has internal systems to meet members’ cultural and linguistic needs. Examples of activities that support these internal systems include:

Initial and continuing training on cultural competency, sensitivity, or diversity for PHC staff, providers and subcontractors.

Regular communication and/or training ensuring that staff and providers are informed and aware of PHC’s policies and procedures regarding provision of CLAS.

Training and educational materials and tools on different cultures and CLAS are made available to PHC staff, and network providers.

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Monitor and evaluate the effectiveness of PHC’s Cultural and Linguistic Services in delivering CLAS is accomplished by review of:

o Member satisfaction surveyso Member complaints and grievanceso Reports of utilization of interpreter service by languageo Provider assessments and site reviewso Findings from the Health Education and Cultural and Linguistic Population

Needs Assessment and Population Health Program Evaluation.o Feedback on services from the Consumer Advisory Committee (CAC), the

Internal Quality Improvement Committee, PHC staff, network providers, community-based organization partners, community health fairs, outreach, and other sources.

As part of the PNA, health disparities and utilization patterns by race, ethnicity, and language are investigated and, when needed, appropriate interventions are implemented.

MPLD7001 Appendix A