NONDISCRIMINATION POLICY AND GRIEVANCE PROCESS 
 

PURPOSE
To prevent hospice personnel or organization from retaliation or discriminating against colleagues, patients or other organizations on the basis of race, color, religion, age, gender, sexual orientation, disability (mental or physical), communicable disease, or place of national origin.

 
POLICY 
In accordance with Title VI of the Civil Rights Act of 1964 and its implementing regulation, SYMPHONY HOSPICE, INC will, directly or through contractual or other arrangement, admit and treat all persons without regard to race, color, or place of national origin in its provision of services and benefits, including assignments or transfers within facilities. 

In accordance with Section 504 of the Rehabilitation Act of 1973 and its implementing regulations, SYMPHONY HOSPICE, INC will not, directly or through contractual or other arrangements, discriminate on the basis of disability (mental or physical) in admissions, access, treatment or employment.  The Executive Director/Administrator has been designated as the coordinator for implementation of this policy. 

In accordance with the Age Discrimination Act of 1975 and its implementing regulation, SYMPHONY HOSPICE, INC will not, directly or through contractual or other arrangements, discriminate on the basis of age in the provision of services unless age is a factor necessary to the normal operation or the achievement of any statutory objective. 
In accordance with Title II of the Americans with Disabilities Act of 1990, SYMPHONY HOSPICE, INC will not, on the basis of disability, exclude or deny a qualified individual with a disability from participation in, or benefits of, the services, programs or activities of the organization. 

In accordance with other regulations, the organization will not discriminate in admissions, access, treatment, or employment on the basis of gender, sexual orientation, religion, or communicable disease. 

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PROCEDURE 

1.    The Section 504/ADA Coordinator designated to coordinate the efforts of SYMPHONY HOSPICE, INC to comply with the regulations will be the Executive Director/Administrator.  Contact the Executive
Director/Administrator at (818) 478-8210.
2.    SYMPHONY HOSPICE, INC will identify an organization or person in its service area who can interpret or translate for persons with limited English proficiency and who can disseminate information to and communicate with sensory-impaired persons.  These contacts will be listed and kept in the policy manual.  (See “Facilitating Communication" Policy No. 1-012.)                                                     Policy No. 1-011.2

3.    A copy of this policy will be posted in the reception area of SYMPHONY HOSPICE, INC, given to all organization personnel, and sent to each referral source.
4.    The following statement will be printed on brochures and other public materials: “Patient services are provided without regard to race, color, religion, age, gender, sexual orientation, disability (mental or physical), communicable disease, or place of national origin.”
5.    Any person who believes he or she has been subjected to discrimination or who believes he or she has witnessed discrimination, in contradiction of the policy stated above, may file a grievance under this procedure. It is against the law for SYMPHONY HOSPICE, INC to retaliate against anyone who files a grievance or cooperates in the investigation of a grievance.
6.    Grievances must be submitted to the Section 504 Coordinator within 30 days of the date that the person filing the grievance becomes aware of the alleged discriminatory action.
7.    A complaint may be filed in writing or verbally, containing the name and address of the person filing it (“the grievant”).  The complaint must state the problem or action alleged to be discriminatory and the remedy or relief sought by the grievant.
8.    The Section 504 Coordinator (or her/his representative) will conduct an investigation of the complaint to determine its validity.  This investigation may be informal, but it must be thorough, affording all interested persons an opportunity to submit evidence relevant to the complaint.
9.    The Section 504 Coordinator will issue a written decision on the grievance no later than 30 days after its filing.
10.    The grievant may appeal the decision of the Section 504 Coordinator by filing an appeal in writing to SYMPHONY HOSPICE, INC within 15 days of receiving the Section 504 Coordinator's decision.
11.    SYMPHONY HOSPICE, INC will issue a written decision in response to the appeal no later than 30 days after its filing.
12.    The Section 504 Coordinator will maintain the files and records of SYMPHONY HOSPICE, INC relating to such grievances.
13.    The availability and use of this grievance procedure does not preclude a person from filing a complaint of discrimination on the basis of handicap with the regional office for Civil Rights of the U.S. Department of Health and Human Services.
14.    All organization personnel will be informed of this process during their orientation process.
15.    SYMPHONY HOSPICE, INC will make appropriate arrangements to ensure that persons with disabilities can participate in or make use of this grievance process on the same basis as the nondisabled.  Such arrangements may include, but not be limited to, the providing interpreters for the deaf, providing taped cassettes of material for the blind, or assuring a barrier-free location for the proceedings.  The Section 504 Coordinator will be responsible for providing such arrangements.

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PATIENT BILL OF RIGHTS 

As a patient, you have the right to: 

•    Be informed of your rights. The Agency must protect and promote the exercise of these rights.
•    The Agency must provide you with written notice of these Rights, including the Statement of Patient Privacy Rights and The Privacy Act Statement and Notice of Privacy Practices in advance of furnishing care or during the initial evaluation procedure.
•    Be free from abuse and neglect.
•    Be treated without regard to race, color, religion, sex age, gender preference, national origin, handicap or decision regarding advance directives.
•    Exercise your Rights as a patient of the Agency.
•    Have you and your property treated with dignity, consideration and respect by qualified professional staff.
•    Know in advance of Agency charges payment policies and if you will be responsible for payment.
•    Be informed both orally and in writing in advance of any change in charges and/or payment responsibilities within 30 days from the day the Agency becomes aware of such changes.
•    Be informed, in advance, of care to be furnished
•    Refuse treatment; be told of the consequences of your actions.
•    Be informed and provided with written information, in advance, about the policy on Advance Directive.
•    Participate in the development of the plan of care/services and discharge plan and be informed of all treatments the agency is to provide, when and how services will be provided and the name functions of any person and affiliated agency providing care/services.
•    Confidentiality of all records, and to refuse release of records to any individual outside the agency except in the case of client transfer to a health care facility or as required by law or third-party payment contract.
•    Have you and your family taught about your illness and treatment required so that you can help yourself and the family can understand and help you.
•    Have access to or receive a copy of your clinical record upon request.
•    Receive timely prior notice of impending transfer or discharge, continuing care requirements, and other available services if needed at the time of discharge from the Agency services.
•    Be spoken to in a language that you understand, have your communication needs met through reasonable assistive device.
•    Voice grievances to the agency regarding lack of respect without being subject to discrimination or reprisal.
•    Have appropriate assessment and management of your pain.
•    Privacy and security.
•    Have your family or guardian to exercise your Rights and Responsibilities in the event you are unable.
•    Contact the state regulatory to file a complaint.

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PATIENT RESPONSIBILITIES 

As a patient, you have the responsibilities to: 

•    Agree to accept all caregivers without regard to race, color, religion, sex, age, gender preference, national origin, handicap or decision regarding advance directives.
•    Remain under a doctor's care while receiving skilled Agency services.
•    Sign require consents and releases prior to care being given or received.
•    Provide the Agency all requested insurance and financial records, and assume responsibility for services not covered by a third-party payor.
•    Provide the Agency with complete and accurate health history.
•    Have appropriate assessment and management of your pain.
•    Participate in developing and following your plan of care.
•    Accept the consequences for any refusal of treatment or choice of noncompliance including changes in reimbursement eligibility.
•    Provide a safe home environment in which your care can be given.
•    Treat Agency personnel with respect and consideration.
•    Advise the Agency of any problems or dissatisfaction with care.
•    Notify the Agency when unable to keep appointments.
•    Provide a copy of an advance directive, if one exists.