Cultural & Linguistic
Program Description
January 2015
MPLD7001
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Program Purpose
Partnership HealthPlan of California (PHC) is committed to delivering culturally and
linguistically appropriate services (CLAS) to all eligible members with limited English
proficiency (LEP) or sensory impairment. PHC’s Cultural and Linguistic Services
comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. Section 2000d, and 45
C.F.R. Part 80) and the Cultural and Linguistic Services requirements in accordance to
the contractual agreement with the Department of Health Care Services (DHCS),
Department of Managed Health Care (DMHC), and the Centers for Medicare and
Medical Services (CMS).
The goal of the Cultural and Linguistic Services Program is to ensure that LEP and
sensory impaired members receive equal access to health care services that are culturally
and linguistically appropriate.
Program objectives include:
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Comply with state and federal guidelines related to caring for LEP and sensory impaired
members.
Improve the quality of health care services for all PHC members at medical and nonmedical points of contact.
Promote a culturally competent health care and work environment for PHC.
Promote CLAS “best practices” for implementation by PHC, its network providers and
subcontractors.
Use outcome, process and structure measures to monitor and continuously improve PHC
activities aimed at achieving cultural competence and reducing health care disparities.
The 2015 Work Plan for the Cultural and Linguistic Services Program at Appendix A includes a
timetable for implementation of activities related to meeting the program goals and objectives.
An illustration of the reporting relationships for PHC identifies key staff with overall
responsibility for the operation of the Cultural and Linguistic Services Program. (See Appendix
B)
The Health Services Department is responsible for developing, implementing and evaluating
PHC’s Cultural and Linguistic Program in coordination with Provider Relations, Member
Services, and Administration/Compliance.
The Quality Management Department (under Health Services), analyzes quality improvement
data by race, ethnicity and language to identify health disparities and utilization patterns as it
relates to Cultural and Linguistic Services.
Provider Relations is responsible for ensuring that provider network composition continuously
meets member’s ethnic, cultural and linguistic needs. Language capabilities of clinicians and
other provider office staff are identified during the credentialing process and through an annual
survey to update PHC’s provider directory.
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Member Services record members’ cultural and linguistic capability upon enrollment using data
acquired from DHCS. Members are informed that they have access to free oral interpretation in
their language and written materials translated into PHC’s threshold languages or provided in
alternative formats. Member Services is responsible for supporting PHC’s Consumer Advisory
Committee (CAC) in accordance with Title 22, CCR, Section 53876 (c). The CAC meetings are
chaired by designated PHC staff. The purpose of the CAC is to provide a link between PHC and
the community. CAC advises PHC on the development and implementation of its cultural and
linguistic accessibility standards and procedures. The committee responsibilities include
advising on cultural competency, educational and operational issues affecting members,
including seniors, persons with LEP, and disabilities. The CAC is composed of PHC members
and community advocates.
Administration is responsible for ensuring that policies and materials for eligible beneficiaries or
potential enrollees do not discriminate due to race, color, national origin, creed, ancestry,
religion, language, age, gender, marital status, sexual orientation, health status or disability.
PHC’s policies and procedures comply with standards and performance requirements for the
delivery of culturally and linguistically appropriate health care services. PHC has systems and
processes to:
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Assess, identify and track linguistic capability of interpreters, bilingual employees and
contracted staff in medical and non-medical settings.
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Conduct a Health Education and Cultural and Linguistic Group Needs Assessment
(GNA) every 5 years for MediCal and annually update the summary report to:
o Identify member health education and cultural and linguistic needs. Submit GNA
reports to DHCS as stated in the contract.
o Continuously develop and improve contractually required health education,
cultural and linguistic services, and educational materials
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Provide cultural competence, sensitivity, or diversity training for staff, providers or
subcontractors at key points of contact.
Monitor and evaluate the Cultural and Linguistic Services and the performance of
individuals providing linguistics services.
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Linguistic services are provided by PHC to monolingual, non-English speaking or LEP Medi-Cal
beneficiaries for population groups as determined by contract. These services include the
following:
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No cost linguistic services:
o Oral interpreters, signers or bilingual providers and provider staff at key points of
contact available in all languages spoken by Medi-Cal beneficiaries
o Written informing materials (to include notice of action, grievance
acknowledgement and resolution letters) fully translated into threshold languages,
upon request
o Use of California Relay Services for hearing impaired.
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PHC regularly assesses and documents member cultural and linguistic needs to determine and
evaluate the cultural and linguistic appropriateness of its services. Assessments cover language
preferences, reported ethnicity, use of interpreters, traditional health beliefs and beliefs about
health and health care utilization. Activities include:
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Document reported ethnicity, preferred language, and use of interpreters in PHC’s
information system.
Document member requests to change their reported ethnicity or preferred language.
Track and analyzing face-to-face and telephonic interpreter service usage rates for all
points of contact.
Instruct providers to record members’ language needs in the medical record and
documenting member requests or refusal of language/interpreter services.
Utilize the results of Facility Site and Medical Record Review audits to validate provider
compliance with documentation requirements.
Utilize the findings and conclusions from the Group Needs Assessment (every 5 years
with annual update) to continuously develop and improve the cultural and linguistic
services program.
Gather additional member input through member surveys, focus groups and grievance
analysis.
PHC continuously assess the linguistic capabilities of its employees, providers and
subcontractors to reduce language barriers, to increase the quality of care LEP members receive,
and ensure the plan’s ability to meet members’ ethnic, cultural and linguistic needs. Activities
that contribute to the assessment process include:
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Employees
o Hire staff that demonstrates appropriate bilingual proficiency at medical and nonmedical points of contact.
o Use a contracted vendor to test PHC employee positions that require bilingual
language proficiency.
o Maintain human resource records on staff linguistic skills and relevant training,
certification and/or proficiency results.
Providers
o Primary Care Providers (PCP) and Specialists are required to ensure access to
care for LEP speaking members through the provider’s own multilingual staff or
through cultural and linguistic services facilitated by PHC.
o Identify language proficiency of bilingual providers and office staff through a
standard self-assessment tool.
o Reporting provider and office staff language capabilities in the Provider
Directory.
Subcontractors
o Execute agreements with subcontractors that include compliance with all product
lines of business requirements.
o Execute agreements with contracted translators and interpreters that require staff
to be tested for proficiency and experience.
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Maintain records in the Health Services department of community health resources
throughout the counties we serve, including the language in which the programs are
offered.
PHC ensures access to interpreter services for all LEP and sensory impaired members through
several mechanisms:
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Inform new enrollees of available linguistic services during a welcome call and in
welcome packets.
Provide a Quick Reference Guide to demonstrate to providers how to access our
interpreter services.
Provide an interpreter for scheduled appointments when requested by the provider or
member.
Ensure that members can use face-to-face language and sign language interpreters with
advance notice.
Make 24-hour access to telephonic interpreter services available for all medical and nonmedical points of contact as defined in the contract or regulations.
Monitor the interpreter request process to avoid unreasonable or unnecessary delays
when the service is requested by the member or provider.
Encourage the use of qualified interpreters rather than family members or friends. (The
member may choose an alternative interpreter at his/her cost after being informed of the
no cost service.)
Discouraging the use of minors as interpreters except in extraordinary circumstances.
Maintain records in the Member Services department of the languages available from the
interpreter services.
Translate all written member informing materials into PHC’s threshold languages and
making materials available in alternative formats as requested, such as Braille, large
print, CD, or audio cassette.
Maintain records in the Member Services department of translated member informing
materials.
Ensure members are made aware that they have the right to file a complaint or grievance
if their linguistic needs are not met.
PHC has internal systems to meet members’ cultural and linguistic needs. Examples of activities
that support these internal systems include:
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Initial and continuing training on cultural competency, sensitivity, or diversity for PHC
staff, providers and subcontractors.
Regular communication and/or training ensuring that staff and providers are informed
and aware of PHC’s policies and procedures regarding provision of CLAS.
Training and educational materials and tools on different cultures and CLAS are made
available to PHC staff, and network providers.
Monitor and evaluate the effectiveness of PHC’s Cultural and Linguistic Services in
delivering CLAS is accomplished by review of:
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Member satisfaction surveys
Member grievances
Reports of utilization of interpreter service by language
Provider satisfaction surveys
Provider assessments and site reviews
Findings from the Health Education and Cultural and Linguistic Group Needs
Assessment and annual updates.
o Feedback on services from the Consumer Advisory Committee (CAC), the
Internal Quality Improvement Committee, PHC staff and network providers,
community-based organization partners, and other sources.
Health disparities and utilization patterns by race, ethnicity, and language are investigated by
PHC’s Quality Improvement Program and when needed, appropriate interventions are
implemented.
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APPENDIX B – As described
in Exhibit A, Attachment 9Access and Availability,
Provision 12; Paragraph 4
Health Education and Cultural and Linguistic Committee
Sonya Bjork, Deputy Chief Operating Officer
Betsy Campbell, MPH - Senior Health Educator
Tammy Fisher, Director of Quality & Performance Improvement
Peggy Hoover, Senior Director of Health Services
Mary Kerlin, Senior Director of Provider Relations
Robert Moore, MD, MPH
Chief Medical Officer
Michelle Rollins, Privacy Officer, Associate Director of Regulatory Affairs
Debbie Shafer, Senior Director of Member Services
Northern Region Staff
Carly Fronfield, Associate Director of Health Services
Kelli Sewell, Director of Member & Provider Services
Susanna Siblisky, Health Educator
The health education staff is responsible for developing, implementing and evaluating
PHC’s Cultural and Linguistic Services in coordination with Provider Relations, Members
Services/Administration/Compliance, and Quality. The senior health educator reports to
the Senior Director of Health Services. All responsible staff/departments report to the
Deputy Executive Director/COO. The Chief Medical Officer and Deputy Executive
Director/COO report to the Chief Executive Officer.
The Director of Member Services has oversight of the Consumer Advisory Committee.
In the northern region: The health educator reports to the Associate Director of Health
Services. The Director of Member and Provider Services, and Associate Director of Health
Services reports to the Executive Director.
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