NONDISCRIMINATION POLICY AND GRIEVANCE PROCESS
Policy No. 1-011.1
To prevent hospice personnel or organization from retaliating 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.
In accordance with Title VI of the Civil Rights Act of 1964 and its implementing regulation, Bright Horizon 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, Bright Horizon 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, Bright Horizon 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, Bright Horizon 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.
The Section 504/ADA Coordinator designated to coordinate the efforts of Bright Horizon to comply with the regulations will be the Executive Director/Administrator. Contact the Executive Director/Administrator at 559-443-0303.
Bright Horizon 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.)
A copy of this policy is posted in the reception area of Bright Horizon, given to all organization personnel, posted on our website, and sent to each referral source.
The following statement has been, and will continue to 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.”
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 Bright Horizon to retaliate against anyone who files a grievance or cooperates in the investigation of a grievance.
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.
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.
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.
The Section 504 Coordinator will issue a written decision on the grievance no later than 30 days after its filing.
The grievant may appeal the decision of the Section 504 Coordinator by filing an appeal in writing to Bright Horizon Hospice Services within 15 days of receiving the Section 504 Coordinator’s decision.
Bright Horizon will issue a written decision in response to the appeal no later than 30 days after its filing.
The Section 504 Coordinator will maintain the files and records of Bright Horizon relating to such grievances.
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.
All organization personnel will be informed of this process during their orientation process.
Bright Horizon 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.