Cultural Competency Plan

Health care services provided by Dell Children’s Health Plan (DCHP) are tailored to meet the needs of the CHIP AND STAR population. DCHP understands the linguistic and cultural competency requirements of its Members and is committed to ensuring that staff and subcontractors are educated about, remain aware of, and are sensitive to the cultural differences and linguistic needs of its Members. To accomplish this goal, DCHP has established a Cultural Competency Plan that builds on DCHP’s experience and relationship with its Members, DCHP staff, subcontractors, and the health care providers. The Cultural Competency Plan is supported by DCHP’s organizational structure.

This Plan is sustained through management and staff who are qualified to meet the needs of the population served. DCHP is committed to employing staff that are bilingual, and will supplement internal bilingual staff with contracts to provide communication, translation, and interpreter services. DCHP’s network includes providers of all specialties who maintain bilingual language capabilities to facilitate communication with patients.

Dell Children’s Health Plan remains committed to promoting the delivery of services, from staff, subcontractors, providers, and all enrollees in a culturally competent manner, including those with limited English proficiency and diverse cultural and ethnic backgrounds, religions, disabilities, and regardless of gender, sexual orientation, or gender identity, in accordance with Title VI of the Civil Rights Act guidelines and the provision of auxiliary aids and services, in compliance with the Americans with Disabilities Act, Title III, Department of Justice Regulation 28 C.F.R. § 36.303, 42 C.F.R. § 438.206(c)(2), and 1 Tex. Admin. Code § 353.411. These provide in part that no persons in the United States must, on the ground of race, color, national origin, sex, age, disability, political beliefs, or religion be excluded from participation in, or denied any aid, care, services or other benefit provided by Federal or State funding, or otherwise be subjected to discrimination.

Policy

It is the policy of Dell Children’s Health Plan to be sensitive to and respect the diverse cultures, races, genders, gender identities and sexual orientation, ethnic backgrounds, religions, and disabilities of its Members, and provide linguistic access and disability related access to all CHIP AND STAR members. The Director of Government Operations and the Director of Member Services will coordinate to present a training program for all Dell Children’s Health Plan staff and subcontractors addressing cultural competencies. This program will be presented annually, and all staff will be required to attend.

All revisions and changes to the Cultural Competency Plan must be submitted to HHSC no later than 30 days prior to implementation of the changes.

Purpose

Guidance

  • To recognize that there are many diverse cultures, races, ethnic backgrounds, religions, gender, sexual orientation, or gender identity and disabilities in Travis and surrounding counties.
  • To develop a staff that recognizes, values, affirms, and respects, the worth of the individuals.
  • To recognize how CHIP AND STAR Members should be treated in order to protect and preserve the dignity of each Member.

Principles

  • Work toward equal access to service and resources for racial and ethnic populations regardless of language, culture, and disability.
  • Respect all Texans and exhibit sensitivity for their cultural practices.
  • Incorporate cultural knowledge and strengths into policy and practice, recognizing the interaction of culture and health.
  • Recognize the diversity within various racial and ethnic communities and distinguish between cultural identification and the culture of poverty.
  • Develop and support a work force at all levels, which reflects the race and ethnicity of the population served.
  • Strive to be cognizant and sensitive to differences in genders, gender identities and sexual orientation while providing compassionate care to all populations.
  • Support programs that strengthen the capacity of multicultural communities to promote health.
  • Establish policies and procedures to promote racial and ethnic community participation in the allocation of resources and the design and implementation of interventions developed to address their needs.
  • Evaluate the effectiveness of programs in improving the health status of racial and ethnic populations.
  • Promote unity through the celebration of diversity.
  • Create an ongoing process to monitor level of cultural competence, including the recognition of achievement and the identification of unmet needs.

Overview

The Cultural Competency Plan will involve the Dell Children’s Health Plan and subcontractors. To address members’ needs, Dell Children’s Health Plan and subcontractors hire linguistically and culturally competent staff. Dell Children’s Health Plan has a system of checks and balances to ensure subcontractor compliance with the civil rights/anti-discrimination laws. This commitment includes ongoing training and periodic reviews of the effectiveness and appropriateness of the plan from Dell Children’s Health Plan and delivery of linguistic and cultural competency services to our members.

Laws and regulations

The [three] major federal legal standards related to cultural competency that Dell Children’s Health Plan adheres to are [Title VI of the Civil Rights Act of 1964], [Federal Executive Order 13166] and the culturally and linguistically appropriate services (CLAS) standards. Additionally, the Texas Health and Human Services Commission (HHSC) has requirements relating to cultural competency that we follow as defined in section 8.1.5.8 Cultural Competency Plan requirements of the UMCC V.2.35

Title VI of the Civil Rights Act of 1964

  • Title VI of the Civil Rights Act of 1964 states that entities, such as companies or corporations, receiving federal financial assistance shall not do any of the following based on protected status:
  • Deny an individual a service, aid or other benefit
  • Provide a benefit that is different or is provided in a different manner
  • Subject an individual to segregation or separate treatment
  • Restrict an individual in the enjoyment of benefits, privileges, etc.
  • Treat an individual differently when determining eligibility
  • Select sites or facility locations that exclude protected individuals

Federal Executive Order 13166

Dell Children’s Health Plan, as a corporation that receives federal financial assistance, must comply with Title VI of the Civil Rights Act of 1964 as well as Executive Order 13166, which sets forth that persons with limited English language skills have meaningful access to services.

Culturally and Linguistically Appropriate Services (CLAS) standards

Dell Children’s Health Plan has adopted all national standards for CLAS in health care. These CLAS standards serve as a guide to Dell Children’s Health Plan to assure that all members entering the health care system receive equitable and effective treatment. Dell Children’s Health Plan is committed to improving quality and eliminating health care disparities through the CLAS standards grouped by theme below.

Principal CLAS standard

CLAS standard one: provide effective, equitable, understandable and respectful quality care and services that are responsive to diverse cultural health beliefs and practices, preferred languages, health literacy and other communication needs.

Dell Children’s Health Plan believes cultural competence impacts every aspect of care and service throughout the corporation, its medical plans and provider network. From the broadest of operational perspectives, this strategic plan provides senior management the direction for health plan and network processes, clinical and administrative policies and procedures to ensure their cultural relevance.

The plan also provides for the structured training of management, staff, and providers to assist in the integration of knowledge, attitudes, and skills reflective of a culturally competent organization. Therefore, the identified cultural competency objectives and strategies address the total organization and network.

Theme one: governance, leadership and workforce

CLAS standard two: advance and sustain organizational governance and leadership that promotes CLAS and health equity through policy, practices and allocated resources.

The cornerstone of the Dell Children’s Health Plan cultural competency program is the top-down, pervasive commitment in our organization. It begins with senior management and extends to employees who have direct contact with members. All commit to the philosophy, objectives, and goals of the cultural competency strategic plan. The Quality Improvement Committee oversees and monitors the operational departments’ implementation of the strategic plan to ensure the provision of health education and outreach services to members and potential members to meet community cultural, linguistic, and social needs.

CLAS standard three: recruit, promote and support a culturally and linguistically diverse governance, leadership and workforce that are responsive to the population in the service area.

Dell Children’s Health Plan provides a high-performance organizational culture of social awareness, values, cultural sensitivity and customer service that supports, attracts and retains a diverse staff. Additionally, Dell Children’s Health Plan strives to hire associates from cultural backgrounds similar to those of our STAR and CHIP members. By doing this, we ensure associates have a greater understanding of our members’ cultural norms, languages, and folk beliefs, which in return enables them to better work with members on treatment options and results in more positive health outcomes.

Dell Children’s Health Plan also strives to hire associates who speak languages similar to those spoken in the areas that we serve. This helps minimize the need for outside interpretation. We are committed to making it easy for our members to access and receive health care, and we are proud of our employee diversity.

CLAS standard four: educate and train governance, leadership, and workforce in culturally and linguistically appropriate policies and practices on an ongoing basis.

Dell Children’s Health Plan associates receive education and training in cultural competency training on an annual basis. The training meets the following goals:

  • To respond to current and projected demographic changes in the United States
  • To continue to improve our quality of services and health outcomes
  • To meet legislative, regulatory and accreditation mandates
  • To coincide with the diversity initiatives of Dell Children’s Health Plan

Upon new hire, Dell Children’s Health Plan requires associates with direct member contact to take cultural competency training. In addition, each year these associates are required to complete a training course on cultural competency as part of the mandatory compliance refresher training. Learning objectives include the ability to:

  • Describe laws and regulations concerning cultural competence
  • Identify the cultural groups served by Dell Children’s Health Plan
  • Assess cultural beliefs that impact a member’s worldview and how these beliefs impact patient care procedures
  • Explore innovative approaches to better serve our culturally diverse members
  • Identify how culture influences a member’s approach to patient care
  • Define approaches that promote self-awareness
  • Identify actions taken to accommodate our diverse members and their families
  • Describe techniques to overcome language barriers

Theme two: communication and language assistance

CLAS standard five: offer language assistance to individuals who have limited English proficiency and/or other communication needs at no cost to them to facilitate timely access to all health care and services.

Dell Children’s Health Plan provides language assistance services, at all points of contact, to members with limited English proficiency or impaired hearing with no cost to the member or provider. We assure the availability of interpreter services through either bilingual staff or qualified interpreters.

Policies are designed to ensure members with low-English proficiency or hearing impairment have meaningful access to health care, assisting them in overcoming barriers, and allowing them to fully utilize services and benefits. In accordance with the Dell Children’s Health Plan member handbook, members have the right to timely access care that does not have any communication or physical access barriers. That includes the right to:

  • Have telephone access with a medical professional [24 hours a day, 7 days] a week to get any emergency or urgent care needed
  • Get medical care in a timely manner
  • Get in and out of a health care provider’s office. In accordance with Americans with Disabilities Act, this includes barrier-free access for those with disabilities or other conditions that limit mobility
  • Have interpreters, if needed, during appointments and when members speak with the medical plan. Interpreters include people who can speak in the member’s native language, help someone with a disability or help the member understand the information
  • Receive information that they can understand about the medical plan rules, including the medical care they can get and how to get it

In order to ensure members have timely access to medical and behavioral health care practitioners and prompt response to telephonic inquiries, Dell Children’s Health Plan annually monitors practitioner appointment accessibility, after-hour accessibility, and telephone accessibility. We use the following data sources to formally assess performance against standards for accessibility at least [annually]:

  • Provider surveys
  • Member Surveys
  • Complaints and grievances related to appointment access
  • Call Center member service telephone statistics

Monitoring of accessibility standards allows for the identification of any issues related to member rights, contractual obligations, and STAR and CHIP requirements. This activity also allows Dell Children’s Health Plan to identify opportunities and make recommendations for actions to improve performance.

Through continued efforts to build prominent and mutual partnerships with our practitioners, Dell Children’s Health Plan is dedicated to assisting members with access to timely medical service and quality care. This commitment is accomplished through ongoing quality process improvement consisting of data collection from member complaints and surveys and multidisciplinary analysis of the data. While there are opportunities to improve access to health care, the established monitoring process has been instrumental in targeting areas for improvement. Accessibility will continue to be monitored [annually] with reporting to the Medical Advisory Committee and the Quality Management Committee. Recommendations from both committees will be incorporated into future monitoring procedures for availability and accessibility standards.

CLAS standard six: inform all individuals of the availability of language assistance services clearly and in their preferred language, verbally and in writing

Language assistance options are available in many different languages and dialects (including Spanish) and are available at no cost to the member.

  • For telephonic services, non-English speaking individuals can call Member Services to connect to an available language line.
  • Oral interpretive services are available either in-office or by telephone. This service is also available at no cost by contacting Member Services.
  • Members who are deaf, hard of hearing or speech impaired can use a telecommunication device for deaf (TDD) or telephone typewriter/teletypewriter (TTY) for telephonic interpretation.
  • Members can also call [711] toll free.
  • In-office sign language assistance is also available and can be arranged by contacting Member Services. (Members needing a language interpreter must call Dell Children’s Health Plan [24] hours before the appointment.)

Members are notified of how to obtain interpretation services in the member handbook, on the member web site, as well as through calls to Member Services.

Providers are able to obtain interpreter services for telephonic contact and in-office visits. Information on how to obtain these services is documented in the provider manual.

CLAS standard seven: ensure the competence of individuals providing language assistance, recognizing that the use of untrained individuals and/or minors as interpreters should be avoided

To the extent possible, Member Service Representatives (MSR) are comprised of associates from similar cultural and linguistic backgrounds as our members. All MSRs receive training on how to assist members with language difficulties and have access to in-house bilingual staff, as well as contracted interpreters via the language line, Language Line. Associates also receive training on how to access local interpreters, and the TDD or TTY. All other interpretive services are provided by professional over-the-phone (OPI) service vendors or locally contracted interpreter service vendors. Oral and written communications with members are offered in the language(s) specified by the state and others are available through OPI interpreters. A toll-free member services number, with access to OPIs, is available for limited English proficient (LEP) individuals. If a member with language difficulties or bilingual needs calls the Member Services line after-hours, they will be routed to the Nurse Helpline. The Nurse Helpline has access to translation services in order to gain translation services. In addition, for those who do not speak English or who are hard of hearing, as noted above under CLAS standard six, Dell Children’s Health Plan can assist members with interpreter services for doctor visits. Associates are trained to offer interpretation services whenever they encounter a member who may benefit from them and educate members about the availability of services.

CLAS standard eight: provide easy-to-understand print and multimedia materials and signage in the languages commonly used by the populations in the service area

Dell Children’s Health Plan assures easily understood member-related materials are available. Documents are available for members in a variety of formats (e.g., large print, Braille, and audio). Written materials, such as member handbooks and member notices, are available in English, Spanish, Braille, large print and by audio upon request. Written member materials are also available in other languages upon request. In addition, all member materials are written at or below a sixth-grade] reading level, according to the Flesch-Kincaid Grade Level scale. Information on our website is available in both English and Spanish.

Theme three: engagement, continuous improvement and accountability

CLAS standard nine: Establish culturally and linguistically appropriate goals, policies and management accountability, and infuse them throughout the organization’s planning and operations

Dell Children’s Health Plan is committed to identifying and addressing health care disparities among our members and within their communities. We endorse the HHSC definition of disparity as the unequal or different treatment or services provided to one group as compared to another group, and we understand that it can refer to how one is treated or the types, quantity or quality of services made available.

Dell Children’s Health Plan looks at continuously improving the quality of care and health outcomes of our members through the implementation of cost effective, evidence-based practices. Associates and committees assess and take action to improve clinical and service quality and safety within the framework of Dell Children’s Health Plan’s core values. Our Cultural Competency plan and annual evaluation define and evaluate tools and processes used to measure and monitor our performance on meeting the members cultural, ethnic and linguistic needs. The annual program description and evaluation are reviewed at Quality Committee at least annually where goals and performance are reviewed and approved.

CLAS standard 10: conduct ongoing assessments of the organization’s CLAS-related activities and integrate CLAS-related measures into assessment measurement and continuous quality improvement

Dell Children’s Health Plan focuses on aligning our cultural competency strategic components with industry standards. Dell Children’s Health Plan develops mission statements and measurable goals to minimize and eliminate health care disparity. The DCHP annual CC program is evaluated annually and taken through to the quality committee to review plan performance and define opportunities for improvement.

Mission:

To reduce health care disparities through culturally sensitive strategies and training to improve Dell Children’s Health Plan member overall health.

Objectives:

  • Provide tools and training to help providers to identify and address health care disparities to improve health outcomes for our members
  • Regularly communicate with member populations that experience health care disparities due to minority, ethnic, or other status
  • Create strategies that positively impact minority group health outcomes
  • Maintain and develop relationships with community partners
  • Increase Dell Children’s Health Plan associate cultural competency awareness to decrease health care disparities

Dell Children’s Health Plan (DCHP) works to improve and provide training materials to associates and the provider network. The program focuses on developing a multicultural health program in order to reduce health care disparities by identifying and developing solutions for members of various racial and ethnic groups. DCHP will leverage our population health strategies and Social Determinants of Health program to identify and address Social Determinants of Health patterns often associated to cultural, ethnic and linguistic determinants of our membership. Dell Children’s Health Plan is committed to partnering with our provider network, community leaders and using membership data while promoting cultural awareness among our associates to reduce these disparities.

CLAS standard 11: collect and maintain accurate and reliable demographic data to monitor and evaluate the impact of CLAS on health equity and outcomes and inform service delivery

Dell Children’s Health Plan considers a multitude of factors while developing this assessment including cultural, ethnic, racial and linguistic needs of the members and providers that serve them.

Dell Children’s Health Plan will leverage this data to improve service and clinical programs, resources for our members and providers and internal processes. The security of this data is maintained in accordance with federal laws governing privacy and protected health information. Members are notified of Dell Children’s Health Plan’s privacy policy and procedures while Dell Children’s Health Plan associates receive [annual] privacy compliance and ethics training.

Racial and ethnic composition: Racial and ethnic composition comes from [daily] membership reports from HHSC state enrollment data. The daily report is used to notify the health plan of the enrollment, disenrollment or any change in participant’s Medicaid eligibility. The member demographic information collected is self-reported on a voluntary basis. We plan to execute more data analysis to ensure there is an alignment with our member and provider demographics.

Primary language data: Primary language data is self-reported at the time of enrollment. Other is used when the member indicates it on the enrollment form. Members in the Other and Unknown categories can possibly be attributed to:

  • The majority of members who do not want to be identified speaking a language other than English.
  • The enrollment form does not clearly explain the intent of the question.

Dell Children’s Health Plan uses an interpreter service vendor to provide language services to our members.

Dell Children’s Health Plan provides language assistance services at all points of contact to members with limited English proficiency or impaired hearing with no cost to the member or provider.

We assure the availability of interpreter services through either case management bilingual staff or qualified interpreters. Language assistance options are available in many different languages and dialects (including Spanish) and are available at no cost to the member.

Initial credentialing for facilities may include an onsite visit and/ or attestations from provider offices to determine compliance with HHSC standards for physical accessibility. Provider directories contain information on the languages that are spoken in provider offices, so that members can make informed decisions when selecting providers. Additionally, translator and face to face interpreter services are available for member office visits to meet membership language needs if the provider office does not offer these services. In the provider manual, providers are educated regarding how to access interpreters for members. They can also reach out to Provider Services for assistance.

We understand our member’s disposition towards accessing and engaging in care and service programs can depend on the trust that comes from shared language and experience, as well as Americans with Disabilities Act-compliant service sites and accessibility of care.

Dell Children’s Health Plan works to recruit and retain a diverse provider network.

We seek primary care providers and specialists located near our members that represent the cultural, ethnic and language preferences of our members and, subsequently, often have life experiences in common with our members. We utilize a local approach to network development by assessing the natural patterns of accessing health care in Texas communities, which are extremely diverse across the state, to identify providers who already serve the population and we target these providers for inclusion in our network.

For members that have language barriers seeing their practitioners, Dell Children’s Health Plan can provide language translators to meet their language needs in the practitioner office.

CLAS standard 12: conduct regular assessments of community health assets and needs and use the results to plan and implement services that respond to the cultural and linguistic diversity of populations in the service area

Dell Children’s Health Plan has a diverse race and ethnic membership. Therefore, we recognize the increasing importance of delivering culturally relevant health care benefits, solutions and education that address the diverse needs of our population. Dell Children’s Health Plan takes an interdepartmental approach and collaboration to help ensure the implementation of culturally and linguistically appropriate health care related services to members with diverse health beliefs and practices, LEP, and variable literacy levels.

Our teams coordinate with community resources both within the Ascension/Seton Healthcare System and with external community partners to leverage multiple programs to assist in meeting the Social Determinants Of Health needs of our members. We also use data collected in our Population Health Assessment to identify the risks of our members, where our members lives and what community resources are available to them in those areas. This data along with our membership demographic data allows us to tie cultural, ethnic and linguistic needs and impacts to our members health care and social needs.

Dell Children’s Health Plan ensures clinical assessment and plans of care reflect relevant cultural issues of the member. Case managers help ensure this by working closely with members and/or their representatives and gathering member feedback in the development of the care plan. Additionally, the member health risk assessment administered by case managers contains questions related to primary language preference and cultural expectations. Plans of care are individualized and reflect appropriate integration and utilization of the member’s culture (to include race and ethnicity as appropriate).

The initial assessment examines a broad range of domains to determine the member’s individual situation and risk of adverse outcomes. These domains include physical and mental health; social, economic and emotional status; capability for self-care; the members’ goals; and the current treatment plan. Assessments are completed via telephone interviews and assess information from the members and/or their representatives. Case managers also obtain information from primary care providers and specialists from early case findings assessments. All of this information is used to determine appropriateness for care management services and to guide, develop and implement the care plan. Care plans are individualized and working closely with the member and/or their representatives, case managers develop care plans that include prioritized long- and short-term goals and the scope, duration, and frequency of services and scheduled re-evaluation of services recommendations. The member’s needs for social, educational, therapeutic, and other nonmedical services are also considered. By working closely with members and/or their representatives, case managers help ensure that members’ cultural needs are met in the development of their individualized care plans.

CLAS standard 13: partner with the community to design, implement and evaluate policies, practices and services to ensure cultural and linguistic appropriateness

Dell Children’s Health Plan develops collaborative relationships with communities to improve health outcomes for members and the community at large. We establish collegial relationships and utilize resources of federally qualified health centers, community-based organizations, advocacy groups and industry partners to provide the broad range of services members may require outside of the scope of the managed care program. Many of these organizations may participate in our community based Member Advisory Meetings as an opportunity to provide input into policies and practices that help DCHP ensure cultural and linguistic appropriate services.

CLAS standard 14: create conflict- and grievance-resolution processes that are culturally and linguistically appropriate to identify, prevent, and resolve conflicts or complaints

Member advocates and liaisons represent the interests of all members. Their responsibilities include handling complaints, ensuring members are informed of their rights and responsibilities and helping them understand their benefits. They serve as ombudsmen and interact with members at events and telephonically. The Member Advocate team investigates each complaint and follows up with the providers’ offices when indicated. Our member services representatives are also trained in culturally competent services and have access to translation services and serve to assist members in identifying, documenting and resolving complaints.

CLAS standard 15: communicate the organization’s progress in implementing and sustaining CLAS to all stakeholders, constituents and the general public

Dell Children’s Health Plan assures stakeholder participation in the service delivery process. Dell Children’s Health Plan recognizes that members receive their advice and guidance from various entities in the community. To that end, on a [quarterly] basis, we hold Member Advisory Group meetings with members to gather feedback and perspectives on a number of topics including: their medical plan, available local community resources, changes in STAR and CHIP programs, and topics proposed by local advisory group participants. Notices are publicly posted on the Dell Children’s Health Plan website in advance of the meetings in dominant languages for the area — specifically [English and Spanish]. These meetings occur in community settings and include member advocates and Community Relations representatives that speak English and Spanish.

In addition, the Member Advisory Group meetings identify and evaluate involvement of community resources. Dell Children’s Health Plan ensures the medical plan member advocate and liaison role includes assisting ethnic and cultural populations. The Member Advisory Group solicits feedback from members and community-based organizations regarding the cultural appropriateness of member materials and programs.

Dell Children’s Health Plan works to ensure that its provider network is able to meet the cultural, racial and ethnic needs, and preferences of its membership. We have recruited medical practices in the communities in which our members live that are more aligned with the racial and ethnic make-up of our membership.

We also monitor access and availability to ensure our network meets the needs of our membership. Our Provider Manual and website offers information on our Cultural Competency Plan and resources available to providers.

Uniformed Managed Care Contract

As a managed care organization (MCO), Dell Children’s Health Plan must comply with the HHSC Uniformed Managed Care Contract and TDI 1 Tex. Admin. Code § 353.411 requirements to have a comprehensive cultural competency strategic plan in place that is compliant to CLAS standards and describes how culturally competent services are administered and linguistic access and disability-related access are provided. The contract also requires the cultural competency strategic plan describe how individuals and systems within the MCO effectively provide services to people of all cultures, races, gender, gender orientation, sexual orientation, ethnic backgrounds, and religions, as well as those with disabilities in a manner that recognizes values, affirms and respects the worth of the individuals, and protects and preserves the dignity of each person.

Summary

In summary, to allow us to better serve our members, Dell Children’s Health Plan is committed to being culturally competent. We do this by recognizing the unique needs of our members and knowing how to successfully communicate vital information about their health care.