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Cultural Competency and Health Equity Reminders

Date: 04/03/23

Member Demographics

Treating the whole patient – not only their conditions – is a major component of delivering quality healthcare. Arizona Complete Health provides information and tools to help make that possible. As of 2021, 26.6% of Arizona residents reported speaking a language other than English, according to U.S. Census data. Arizona Complete Health identifies 15 non-English languages meeting a viable threshold among members in 2022: Spanish, Navajo, Chinese, Vietnamese, Arabic, Tagalog, Korean, French, German Russian, Japanese, Persian, Syriac, Serbo-Croatian, and Thai.

Member Rosters

In the Provider Portal, the Patient List that is available includes member preferred languages. The list can be sorted by language so you may garner language needs of your members and prepare for interpretation needs accordingly.

Language Identification Tools

Keeping a language identification tool in your lobby so members can easily let you know what language they speak. A language identification tool is a commonly a poster or a flyer where members may point to their language, and the need for an interpreter can be easily identified. You can access a language identification tool by going to our website Arizona Complete Health and clicking on “Language Assistance” in the footer at the bottom of the home page. If the member’s a language is not listed, you can still work with the interpreter service to identify the right language.

Check the end of this communication for additional language assistance information.

National CLAS Standards

All 15 of the National Standards for Culturally and Linguistically Appropriate Services in Health and Health Care (CLAS) need to be implemented in care. Think Cultural Health, a division of the Office of Health and Human Services, has a variety of resources on CLAS implementation. These include:

·         Behavioral Health Implementation Guide for the National Standards for Culturally and Linguistically Appropriate Services in Health and Health Care

·         Blueprint for Advancing and Sustaining CLAS Policy and Practice

Health Disparities

Health equity is the attainment of the highest level of health for all people (U.S. Department of Health and Human Services [HHS] Office of Minority Health, 2011).  Health disparity data should be utilized to enhance service delivery. Providers are encouraged to analyze this data regularly to identify disparities, fill gaps in services, and to develop and implement strategies to eliminate barriers for health equity within your organization. Resources to obtain health disparity information include:

1.       Center for Disease Control  

2.       Arizona Health Disparities Center

3.       Rural Health Disparities

4.       Health-mapping every zip code in Arizona

5.       Healthy People 2020

6.       U.S. Department of Health and Human Services Office of Minority Health

7.       Review Community Needs Assessments

a)       Identify areas to address such as these taken from the Pima County Community Needs Assessment: addressing access to care, health literacy, transportation, housing resources, access to nutritious foods, increased screenings, access to physical activity, undiagnosed mental illness, substance misuse and need for sobriety centers for people experiencing homelessness, and more Health Data, Statics and Reports 

b)      Newly released – 2020 Statewide Maternal and Child Health Needs Assessment

c)       Maricopa County

d)      Cochise County

e)      Graham County

f)        Facilitate a focus group on needs, barriers, gaps

Language Assistance

Federal law requires that healthcare providers provide services in a culturally competent manner and accessible to all members, including those with limited-English proficiency (LEP), limited reading skills, who are deaf or hard of hearing, or have diverse cultural and ethnic backgrounds. In accordance with Title VI of the Civil Rights Act, ACOM 405-Cultural Competency and Family Centered Care, Prohibition Against National Origin Discriminations, the President’s Executive Order 131166, the National Culturally and Linguistically Appropriate Service (CLAS) Standards, and section 1557 of the Patient Protection and Affordable Care Act, the Health Plan and its providers must make language assistance available to persons with Limited English Proficiency (LEP) at all points of contact during all hours of operation at no charge. In addition, members must receive information instructing them on how to access these services. Notices of language assistance include:

·         Per 42 CFR 438.10 and 45 CFR 92.8, providers must post nondiscrimination notices and language assistance taglines in lobbies and on websites. Language assistance taglines notify individuals of the availability of language assistance in at least the top 15 languages utilized in Arizona and must include at least one tagline in 18-point font.

·         For more information these requirements, visit the Code of Feberal Regulations.

Arizona Complete Health offers participating providers and members access to telephone, face-to-face interpreters, and video remote interpreters (VRI) during business hours at no cost. To make a request, providers need to call the Provider Customer Contact Center at 1-866-796-0542.

Language Assistance Reminders:

1.       Members are not required to schedule or bring an interpreter with them. It is the responsibility of the provider to ensure the interpreter is secured for appointments.

2.       The best practice is to provide interpretation with certified bilingual staff. To become certified, staff are tested by a language vendor and meet a minimum score of 8-Advanced Minus or higher.

3.       It is the responsibility of the provider to ensure the interpretation is secured for the appointment, not the member.

4.       Please schedule the interpreter at least 5 business days ahead of the appointment to allow time for the language vendors to secure one.

5.       Interpretation vendors charge a two-hour minimum for interpreters, whether the appointment time is 15 minutes, 30 minutes, etc. When possible, please group appointments for members who speak the same language so the same interpreter may be used, and their time can be effectively managed.

6.       Our language vendor resources are an option as a courtesy to help offset the cost of interpretation. Providers are required to also maintain their own contracts to meet the language assistance needs when Arizona Complete Health vendor interpreters are unavailable.

7.       Please do not reschedule the appointments multiple times due to an interpreter being unavailable because this will cause unreasonable delays in accessing care. Members have a right to equitable access to care and effective communication and may be able to file a discrimination lawsuit against any provider who does not meet their needs.

8.       Telehealth: When you secure a Telehealth appointment, inform them of the need for an interpreter. Note: Some deaf or hard of hearing members may have TTY capabilities. Dial 711 and the operator will ask what number you are calling and will connect the call.

A Provider shall Not:

·         Require an individual with limited English proficiency to provide their own interpreter.

·         Rely on an adult or minor child accompanying an individual with limited English proficiency to interpret or facilitate communication, except:

o   In an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no qualified interpreter for the individual with limited English proficiency immediately available;

o   Where the individual with limited English proficiency specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances;

·         Rely on staff other than certified qualified bilingual/multilingual staff to communicate directly with individuals with limited English proficiency.

Reporting T1013 (Behavioral Health Only)

Behavioral health providers report usage of Language Assistance - T1013, Interpretation

·         T1013 is reported when providing language assistance delivered by certified bilingual staff or provided by a language vendor or any qualified interpreter. This code is used to track language assistance that is being provided at any time (languages other than English, including ASL). T1013 does not require a modifier.

·         Interpretation is reported in conjunction with another service that cannot be delivered effectively without the availability of sign language or interpreter assistance, never a standalone code.

·         Does not include a value/is not reimbursed.

Written Materials

It’s required that you provide easy-to-understand print and member information materials, materials in alternative formats, as well as signage in the languages commonly used by the populations in your service area. This includes the production of materials with consideration of members with LEP or limited reading skills, those with diverse cultural and ethnic backgrounds, and those with visual or auditory limitations. Providers must provide written translation to members with LEP upon request, at no charge. Some considerations:

·         For Medicaid, per ACOM 405 Cultural Competency and Family Centered Care, all written materials for members shall be translated into Spanish regardless of whether or not they are vital. In addition, oral interpretation services shall not substitute for written translation of vital materials.

·         In general, any document that requires the signature of the Member, and that contains vital information such as the treatment, medications or notices, or service plans must be translated into their preferred/primary language upon request.

508 Accessibility Compliance

·         In 1998 the US Congress amended the Rehabilitation Act to require Federal agencies to make their electronic and information technology accessible to people with disabilities.

·         Materials posted to your website need to be made 508 compliant before they can be posted on the website. This is to ensure the documents meet the requirements for readability by persons with disabilities. For more information about the 508 requirements, click here.

Data Collection

Approximately 48% of member race and ethnicity is unknown, and approximately 26% of member language is undetermined. As you talk with members, please update records as applicable to ensure their cultural needs are being met.

Annual Cultural Competency Training

Providers are required to offer services in a culturally and linguistically sensitive manner and to provide new employee and annual cultural competency training. To meet the training requirements, we encourage you to take the cultural competency training located on our website: Arizona Complete Health. Providers who take this training will receive a certificate of completion.

You may also search for cultural trainings in the Relias Learning System. Some culturally related trainings in Relias include:

1.       Understanding and Minimizing Cultural Bias for Paraprofessionals

2.       A Culture-Centered Approach to Recovery

3.       Diversity, Equity, and Inclusion for the Healthcare Employee

4.       Influence of Culture on Care in Behavioral Health for Paraprofessionals

5.       Cultural Responsiveness in Clinical Practice

6.       Diversity and Disability

7.       Humility and Respect in Healthcare

8.       Cultural Competence and Healthcare

9.       Implicit Bias for the Healthcare Professional

10.   Understanding and Minimizing Cultural Bias for Paraprofessionals

11.   Understanding and Addressing Racial Trauma in Behavioral Health

12.   Diversity, Equity, and Inclusion for the Healthcare Employee

In addition, we encourage you to attend cultural competency courses through the U.S. Department of Health and Human Services (HHS) Office of Minority Health (OMH) as part of their continuing education at Think Cultural Health. Training topics offered include:

1.       Culturally and Linguistically Appropriate Services (CLAS) in Maternal Health Care

2.       A Physician’s Practical Guide to Culturally Competent Care  

3.       Cultural Competency Program for Oral Health Providers

4.       Culturally Competent Nursing Care: A Cornerstone of Caring

5.       The Guide to Providing Effective Communication and Language Assistance Services

6.       Improving Cultural Competency for Behavioral Health Professionals

For any questions, please contact