By Rose Willis
- Notice Statement. The entity must post a Notice informing patients of Non-Discrimination and Accessibility Requirements. We recommend that entities post the Notice in the form that has been approved by OCR, located here: http://www.hhs.gov/sites/default/files/sample-ce-notice-english.pdf. The Notice must be posted in a visible font size in the following 3 areas:
- (i) In significant publications and significant communications targeted to beneficiaries, enrollees, applicants, and members of the public, except for significant publications and significant communications that are small-sized, such as postcards and tri-folds brochures;
- (ii) In conspicuous physical locations where the entity interacts with the public; and
- (iii) In a conspicuous location on the covered entity’s Web site accessible from the home page of the covered entity’s Web site.
- Taglines. The entity must also post “Taglines” in the same 3 areas stated above, informing individuals with limited English proficiency of language assistance services. The Taglines must be posted in the top 15 languages spoken by individuals with limited English proficiency in the State. In Michigan, those languages are Spanish, Arabic, Chinese, Syriac, Vietnamese, Albanian, Korean, Bengali, Polish, German, Italian, Japanese, Russian, Serbo-Croatian, and Tagalog.
- While the taglines will not need to be posted in English, it effectively states: Proficiency of Language Assistance Services ATTENTION: If you speak [insert language], language assistance services, free of charge, are available to you. Call 1-xxx-xxx-xxxx.
- The translated versions of the taglines in each of these languages have been provided by the Government for your use, and are available here: http://www.hhs.gov/civil-rights/for-individuals/section-1557/translated-resources/index.html
- Postings in Small Sized Publications/Communications. In addition, the entity must post the following in significant publications and significant communications that are small-sized, such as postcards and tri-folds brochures.
- The taglines described above in the top 2 languages spoken by individuals with limited English proficiency in the State. In Michigan, those languages are Spanish and Arabic; and
- A brief Statement of Non-Discrimination as follows: [Name of Entity] complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex.
- Grievance Procedure/Coordinator. In addition, if the entity employs 15 or more employees, it must adopt a grievance procedure and designate a responsible employee to act as the grievance coordinator (this could be the same person as the person who acts as current compliance coordinator). A sample grievance procedure has been developed by OCR for your use, and it can be found here: http:///www.hhs.gov/sites/default/files/section-1557-sample-grievance-procedure.pdf
While we recommend using the forms developed by OCR, each entity will need to tailor those forms to at least incorporate its specific contact information.