North Country Community Mental Health
Northern Affiliation
CULTURAL COMPETENCY PLAN
Introduction
In 1997, the US Department of Health and Human Services (HHS), Office of Minority Health (OMH) asked
Resources from Cross Cultural Health Care and the Center for the Advancement of Health to review and
compare existing cultural and linguistic competence standards and measures in a national context,
propose draft national standard language where appropriate, assess the information or research needed
to relate these guidelines to outcomes, and develop an agenda for future work in this area. This resulted
in recommendations for National Standards and an Outcome –Focused Research Agenda submitted to
OMH in May 1999. The draft CLAS (cultural and linguistically appropriate services) standards were
published in the Federal Register on December 15, 1999 (Volume 64, Number 240, pages 70042-70044),
and full report for individuals’ and organizations’ review and comment from January 1 to April 30, 2000.
The final report and standards by the Office of Minority Health, National Standards on Culturally and
Linguistically Appropriate Services (CLAS) in Health Care were published in the Federal Register:
December 22, 2000 (Volume 65, Number 247). The Final Report publication put out by the US
Department of Health and Human Services, dated March 2001, Washington DC sets forth 14 Standards.
The 14 Standards are organized by themes: Cultural Competent Care (Standards 1-3), Language
Access Services) Standards 4-7), and Organizational Supports for Cultural Competence (Standards 814). Within this framework, there are three types of standards of varying stringency: mandates,
guidelines, and recommendations. Standards 4, 5, 6, and 7 are CLAS mandates that are current
requirements for all recipients of Federal funds. Standards 1, 2 3, 8, 9, 10, 11, 12, and 13 CLAS
guidelines are activities recommended for adoptions and mandates by Federal, State, and national
accrediting agencies. Standard 14 CLAS recommendation is suggested by Office of Minority Health
(OMH) for voluntary adoption by health care organizations. Standards are attached as Attachment A to
this plan.
Purpose
It is the responsibility of NCCMH – Northern Affiliation to ensure contracted providers take reasonable
steps to facilitate appropriate cultural competence in the provision of mental health and substance abuse
services.
The purpose of this plan is to clarify the responsibilities of NCCMH – Northern Affiliation in ensuring that
people entering mental health and substance abuse services receive equitable treatment in a culturally
and linguistically appropriate manner.
Application
North Country Community Mental Health is both a Medicaid specialty prepaid inpatient health plan (PIHP)
and a service provider. This plan is intended to address both aspects of the organization’s operations. It
is the intent of NCCMH that the scope of the Cultural Competency Plan should promote equitable
treatment in a culturally and linguistically appropriate manner.
The Northern Affiliation is a division of NCCMH that performs the managed care functions of the PIHP.
NCCMH is authorized to perform these functions for a thirteen county area through an Intergovernmental
Transfer of Functions and Responsibility Act agreement. The Affiliation’s Cultural Competency Plan
applies to all NCCMH services, providers, and subcontractors providing services under contract with
NCCMH – Northern Affiliation.
General Overview
It is acknowledged that efforts to provider equitable mental health and substance abuse treatment in a
culturally and linguistically appropriate manner to consumers must be organization wide and must be
ongoing. In order to assure that these efforts are sustained, compliance to the Cultural Competency Plan
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is developed from the performance improvement perspective. Assuring this compliance, both
prospectively and retrospectively, is best done through focus on improvement, utilizing objective data,
systems analysis, and feedback.
Administrative Responsibilities
Primary responsibility for implementing and monitoring compliance to the Affiliation’s Cultural
Competency Plan shall be assigned to the Regulatory Compliance Coordinator. The Compliance
Coordinator will, with oversight from the Director of Affiliation Services, perform the following activities:

Review and amend the Cultural Competency Plan (CC Plan), as necessary, based on changes in the
laws and regulations that govern cultural competency standards.

Develop methods to ensure that employees and provider organization staff are aware of the CC
Plan/policies, and are aware of the importance of ensuring equitable treatment in a culturally and
linguistically appropriate manner.

Ensure that employees and provider organization staff are educated and trained in the cultural
competence standards.

Monitor at least annually for appropriate training of staff, and that appropriate data gathering is
occurring.

Initiate corrective actions for identified deficiencies in implementation and maintenance of cultural
competence standards.

Develop processes to identify the number or proportion of culturally diverse persons in the population
to be served or likely to be encountered by the provider or service.

Develop processes for identifying and reporting data pertinent to tracking cultural diverse person’s
needs and future needs.
Administrative Plan
Each provider operation shall appoint a representative to serve as the Cultural Competency leader for
that organization’s activity. The CC leader will coordinate cultural competency activities. (See Northern
Affiliation Administrative Manual, 6/18/02 Operations Committee approved “Policy Regarding Cultural
Sensitivity.”) The Regulatory Compliance Coordinator will have regular contact with the CC leaders about
matters of common interest.
Each provider organization is responsible for the development and implementation of a plan to address
Cultural Competency compliance efforts. These plans shall, at a minimum, include the following features:

Written policies and procedures for operational activities undertaken by the organization personnel,
including any specialty specific standards that may be relevant;

Education and training programs to ensure staff have a working knowledge of cultural competency
standards;

A system ensuring and documenting that all new personnel receive training regarding cultural
competency standards;

A system ensuring and documenting that staff receive annual cultural competency training;

A process for routine “spot checks” of cultural competency activities with the results of such review
being reported to the CC leader and the Affiliation’s Compliance Coordinator;

A system that tracks the cultural diversity in service requests and provision of services, as well as
issues that have been raised within the organization and the resolution of those issues;

A process to assess and analyze community need, and implementation of policy/procedures to meet
needs identified;

A process for availability of interpreter services when needed.
Policy Guidelines
The Cultural Competency Plan will be reviewed annually, and revised as necessary. Cultural
Competency training will be a part of new employee orientation and staff annual training.
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Definitions
Definitions used here can be found in: Cross T., Bazron, B., Dennis, K., & Isaacs, M. (1989). Towards a
Culturally Competent System of Care, Volume I. Washington DC: Georgetown University Child
Development Center, CASSP Technical Assistance Center.
The idea of more effective cross-cultural capabilities is captured in many terms similar to cultural
competence. Cultural knowledge, cultural awareness, and cultural sensitivity all convey the idea of
improving cross-cultural capacity, as illustrated in the following definitions:
Cultural Knowledge: Familiarization with selected cultural characteristics, history, values, belief
systems, and behaviors of the members of another ethnic group (Adams, 1995).
Cultural Awareness: Developing sensitivity and understanding of another ethnic group. This usually
involves internal changes in terms of attitudes and values. Awareness and sensitivity also refer to the
qualities of openness and flexibility that people develop in relation to others. Cultural awareness must be
supplemented with cultural knowledge (Adams, 1995).
Cultural Sensitivity: Knowing that cultural differences as well as similarities exist, without assigning
values, i.e., better or worse, right or wrong, to those cultural differences (National Maternal and Child
Health Center on Cultural Competency, 1997).
However, cultural competence is defined as a set of congruent behaviors, attitudes, and policies that
come together in a system, agency, or among professionals and enables that system, agency, or those
professionals to work effectively in cross-cultural situations (Cross, Bazron, Dennis, & Isaacs, 1989).
Operationally defined, cultural competence is the integration and transformation of knowledge about
individuals and groups of people into specific standards, policies, practices, and attitudes used in
appropriate cultural settings to increase the quality of health care; thereby producing better health
outcomes (Davis, 1997). Cultural competency emphasizes the idea of effectively operating in different
cultural contexts. Knowledge, sensitivity, and awareness do not include this concept. “This is beyond
awareness or sensitivity,” says Marva Benjamin of the Georgetown Technical Assistance Center for
Children’s Mental Health.
REFERENCES
US Department of Health and Human Services, OPHS – Office of Minority Health; “National Standards for
Culturally and Linguistically Appropriate Services in Health Care,” FINAL REPORT, March 2001,
Washington, DC
The Office of Minority Health, Public Health Services, US Department of Health and Human Services –
Cultural Competency Standards, “Assuring Cultural Competence in Health Care,” Summary
SAMHSA’s National Mental Health Information Center, Cultural Competency Standards in Managed Care
Mental Health Services, Section II – Overall System Standards and Implementation Guidelines
Federal Register: December 22, 2000 (Volume 65, Number 247); Notices: Pages 80865-80879
Federal/National Partnership Cultural Competency Task Force, Center of Mental Health Services,
Meeting Summary Report Dated April 29, 1998, Washington, DC
Newsletter of the Office of Minority Health, Mental Health and Minorities, September 1997
Cultural Competence web site: www.air-dc.orgcecp/cultural/
 “How is this different than Cultural Sensitivity Awareness?” (Definitions)
 “Who Should be Involved?” (Clarifies not just an issue for mental health service providers)
 “How Do I Start?” (Checklist)
Developing Cross-Cultural Competence, authors Eleanor W. Lynch and Marci J. Hanson – Chapters 1, 2,
and 3
2004 – Revised:
Approved by:
North Country CMH Board, May
2005
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North Country Community Mental Health (NCCMH)
NORTHERN AFFILIATION
LIMITED ENGLISH PROFICIENCY PLAN
Introduction
Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency”,
dated August 11, 2000 requires mental health service providers to assess and address the needs of
otherwise eligible persons seeking access to services, who, due to Limited English Proficiency (LEP),
cannot fully and equally participate in or benefit from services provided by community mental health
programs receiving federal funds.
It is the responsibility of NCCMH – Northern Affiliation to ensure all contracted providers take reasonable
steps to facilitate meaningful access to the mental health and substance abuse services for persons with
limited English proficiency.
Purpose
The purpose of this plan is to clarify the responsibilities of NCCMH – Northern Affiliation for providing
persons with limited English proficiency meaningful access to mental health and substance abuse
programs, services, and other information those entities provide.
Application
North Country Community Mental Health is both a Medicaid specialty prepaid inpatient health plan (PIHP)
and a service provider. The plan is intended to address both aspects of the organization’s operations. It
is the intent of NCCMH that the scope of the Limited English Proficiency Plan should promote reasonable,
meaningful access to services.
The Northern Affiliation is a division of NCCMH that performs the managed care functions of the PIHP.
NCCMH is authorized to perform these functions for a thirteen county area through an intergovernmental
Transfer of Functions and Responsibility Act agreement. The Affiliation Limited English Proficiency Plan
applies to all NCCMH services, providers, and subcontractors providing services under NCCMH –
Northern Affiliation’s PIHP.
General Overview
It is acknowledged that efforts to maintain reasonable and meaningful access to mental health and
substance abuse services for LEP consumers must be organizational wide and must be ongoing. In
order to assure that these efforts are sustained, compliance to the LEP plan is developed from the
performance improvement perspective. Assuring this compliance, both prospectively and retrospectively,
is best done through a focus on improvement, utilizing objective data, systems analysis, and feedback.
Administrative Responsibilities
Primary responsibility for implementing and monitoring compliance of the Affiliation’s LEP plan shall be
assigned to the Regulatory Compliance Coordinator. The Compliance Coordinator will, with oversight of
the Director of Affiliation Services, perform the following activities:

Review and amend the LEP plan, as necessary, based on changes in the laws and regulations that
govern LEP standards;

Develop methods to ensure that employees and provider organization staff are aware of the LEP
plan/policies, and are aware of the importance of ensuring meaningful access to persons with limited
English proficiency to services;

Ensure that employees are provider organization staff are educated and trained in the LEP
process;

Monitor, at least annually, the frequency of LEP individuals in services, the training of staff, and that
appropriate data gathering is occurring;
Initiate corrective actions for identified deficiencies in implementing and maintaining LEP processes;

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
Develop a process to identify the number or proportion of LEP persons eligible to be served or likely
to be encountered by the provider or service;

Develop processes for identifying and reporting data pertinent to tracking LEP needs and
future needs.
Administrative Plan
Each provider operation shall appoint a representative to serve as the LEP leader for that organization’s
activity. The LEP leaders will coordinate limited English proficiency activities. (See Northern Affiliation
Administrative Manual, Chapter 2 – Policy 2004 for activities to be included.) The Regulatory Compliance
Coordinator will have regular contact with the LEP leaders about matters of common interest.
Each provider organization is responsible for the development and implementation of a plan to address
LEP compliance efforts. These plans shall, at a minimum, include the following features:

Written policies and procedures for operational activities undertaken by the organization personnel,
including any specialty specific standards that may be relevant to LEP;

Educational and training programs to ensure staff have a working knowledge of LEP requirements;

A system ensuring and documenting that all new personnel receive training regarding LEP
requirements;

A process for routine “spot checks” of LEP activities, with the results of such review being reported to
the LEP leader and the Affiliation’s Compliance Coordinator;

A system that tracks LEP contacts, as well as issues that have been raised within the organization
and the resolution of those issues;

A process for availability of interpreter services when needed.
Policy Guidelines
The LEP policy will be reviewed annually, and revised as necessary. LEP training will be part of new
employee orientation and staff annual training.
REFERENCES
The White House: Executive Order 13166 – “Improving Access to Services for Persons with Limited
English Proficiency”, August 11, 2000
Government Publication: Brochure title “Know Your Rights – Are you limited English Proficient? (LEP)”
Government Publication: Fact Sheet title “Facts About National Origin Discrimination”. Web version page
updated June 28, 2002
Department of Justice Publication: “Limited English Proficiency (LEP) Access Plan,” Office of the
Chairman, January 25, 2002. Note: Interpretation of Executive Order 13166
Department of Justice – Civil Rights Division: “Commonly Asked Questions and Answers Regarding
Executive Order 13166.” Web version page updated April 11, 2002
Department of Justice: Departmental Plan Implementing Executive Order 13166.” Web version page
updated January 10, 2001
2004 – Revised:
Approved by:
North Country CMH Board, May 2005
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