The Center for Progress and Excellence Inc.
DEPARTMENT: Administration
SUBJECT: Auxiliary Aids Plan
DATE ADOPTED: 08/24/2020 DATE REVIEWED/REVISED: 10/25/2023
PURPOSE:
It is the Department’s obligation to ensure effective communication with customers or companions who are deaf or hard of hearing. To meet this obligation, the Department must first distinguish between aid essential communication situations and non-aid essential communication situations and to secure appropriate auxiliary aids or services for each situation.
POLICY
The Center for Progress and Excellence Inc (CPE) has established this Auxiliary Aid Plan in accordance with Section 504 of the Rehabilitation Act to comply with the Deaf and Hard‐of‐Hearing requirements. The purpose is to establish guidelines for ensuring the provision of services to clients and companions who may be hearing impaired or have limited English proficiency. All Deaf and Hard‐of‐Hearing customers/companions in need of Auxiliary Aids will be offered these services at no additional cost as per Federal Law and contractual agreement. The Center for Progress and Excellence Inc. has assigned a Single‐Point‐of‐Contact (SPOC), who is essentially responsible for maintaining files that document the required information for the Deaf and Hard‐of‐Hearing.
PROCEDURES
Assessing for Communication Needs
At the initial point of contact, an assessment of communication needs will be conducted for all individuals or companions who are Deaf or Hard‐of‐Hearing.
The appropriate Department of Children and Families documents will be completed on the initial visit and at each interaction/service to the client or companion. The purpose of these tools is to facilitate the collection and coordination of auxiliary aids and services provided to Customers or Companions who are Deaf or Hard‐of‐Hearing. The client or companion’s auxiliary aid preference will be identified on the Customer or Companion Communication Assessment and Auxiliary Aid and Service Record and will be the primary consideration as to what device or service is provided. The SPOC will be responsible for ensuring auxiliary aid documents are maintained appropriately and accessible upon request as evidence services were provided. Records, documents, and forms that outline the use of these services will be kept by The Center for Progress and Excellence for seven years. After seven years, all records, documents, and forms will be disposed of following HIPAA guidelines.
Request for a Certified Interpreter
A certified interpreter should be available at the time of the scheduled appointment. If the interpreter fails to appear additional steps will be taken to provide an interpreter no later than two (2) hours after the scheduled appointment.
For unscheduled appointments, an interpreter should be provided within two (2) hours of the request if the situation is determined emergent. For non‐emergent situations, an offer will be made to schedule the appointment by the next business day.
Requests for Certified Interpreter services may be made to the Deaf Service Center of Southwest Florida. Online scheduling is available (https://cpfamilynetwork.org/resources/resources-guide/deaf-service-center-of-southwest-florida-inc/) for scheduled appointments and a 24-hour on-call service is available for unscheduled or emergency visits through the emergency line at (239) 461‐0334. Alternative resources are available through Staff Development if needed.
If the client or customer has identified the need for a qualified foreign language interpreter due to language barriers or limited English proficiencies, one will be made available at the time of the scheduled appointment. The SPOC shall obtain verification of the interpreter’s certification which will be maintained in a DHOH binder located in the SPOC’s office. The SPOC will maintain a list of ASL and foreign language interpreters for staff reference.
Non-Effective Auxiliary Aid Services
When it is determined that the auxiliary aid and service provided was not effective, staff shall conduct a reassessment of the communication needed to determine the appropriate alternative auxiliary aid. When staff has determined that the interpreter did not meet their own or the customer or companion’s expectations, they will document in Section 3 (Additional Service Required) of the Customer or Companion Communication Assessment and Auxiliary Aid and Service Record and indicate what additional steps were taken by staff.
Denial of Auxiliary Aid/Service
· A denial of an auxiliary aid and service should only be done when it is a non‐aid essential communication.
· Staff must still ensure that effective communication is achieved through whatever alternative means is provided.
· The Center for Progress and Excellence staff must provide a reason for denial of service.
· Denials can only be made by the SPOC or designee.
· Staff is required to document the name and title of the person who made the denial determination, along with the time and date.
Client/Customer Complaints or Grievances
The Department of Children and Families Customer/Companion Feedback forms will be provided by CPE to allow clients or companions an opportunity to provide feedback to the Office of Civil Rights, Department of Children and Families. The Center for Progress and Excellence Inc. does not maintain copies of the completed feedback form.
Client or Companion complaints will be referred to the Quality Improvement Department and an attempt will be made to resolve those complaints by the Clinical Director. Client or Companion complaints can also be made to the Office of Civil Rights (OCR) or the United States Department of Justice (USDOJ). Information will be made available upon request.
Alternative Listening Devices
Clients and Companions who are Deaf or Hard‐of‐Hearing will be advised of available alternative listening devices and informed of how to use those devices.
· The Florida Relay, dial 7‐1‐1, or use the following toll-free numbers:
o 800‐955‐8771 (TTY)
o 877‐955‐8770 (Voice)
o 800‐955‐1339 (ASCII)
o 877-955-8260 (Voice Carry Over -VCO)
o 877‐955‐5334 (Speech to Speech-STS)
o 877-955-5334 (Video Assisted STS)
o 877‐955‐8733 (Spanish)
o 877‐955‐8707 (French Creole)
· The Center for Progress and Excellence Inc. does not have access to TDD/TYY equipment but can accept phone calls from individuals who use these methods of communication.
· Information on Pocket Talkers and Personal Listening Devices is available upon request.
(Individuals can apply for free Specialized Telecommunications Equipment here: https://www.ftri.org/free )
· Information on the Federal Video Remote Interpreting (VRI) and Video Relay Interpreting Service (VRS) services. Providers for the Video Remote Interpreting software can be found at https://www.fcc.gov/vrs-providers and the phone number is 888‐ 225‐5322. The Center for Progress and Excellence does not currently have access to the equipment needed for Video Remote/Relay Interpreting but can accept phone calls from individuals who use these methods of communication.
· Information is available on how to use the Captioning in Real Time Services (CART). CART providers can be found online at http://psl.ncra.org/index.asp A list of CART providers in Florida is maintained in the Quality Improvement Department.
Training
Training is essential to the ongoing success of providing auxiliary aids and services to persons with disabilities or those who are Limited English Proficient.
New employee training will include the Department of Children and Families online training on “Serving our Customers who are Deaf or Hard‐of‐Hearing”, Chapters 1, 2, 3. This will be completed within 60 days of commencing employment for all staff providing direct client services.
All staff will receive training annually on how to provide assistance to persons with disabilities and who are Limited English Proficient. This training is mandatory and will be tracked in the staff development files.
If staff remain unclear on the process for using auxiliary aids or services after conducting the Department of Children and Families online training, staff should schedule individual training with the organization’s SPOC.
Public Notice for Auxiliary Aid Services
If the Center for Progress and Excellence Inc. holds a public meeting, conference, or seminar, an addendum to the documents advertising the events will be added, stating: “Pursuant to the provisions of the Americans with Disabilities Act, any person requiring special accommodations to participate in these meetings is asked to advise the agency at least 48 hours before the meeting by contacting Heather Cross at (239) 689-8490. If you are hearing or speech impaired, please contact the agency using the Florida Relay Service, 800‐ 955‐8771 (TTY) or 800‐955‐8770 (voice).”
A copy of this Auxiliary Aid Plan will be posted on CPE’s website to be made available to the public for informational purposes for both individuals and organizations. Printed documents (including this Auxiliary Aid Plan) may be made available in alternate formats upon request to assist in ensuring effective communication and will depend upon the customer or companion’s preferred method. Staff may be required to translate written documents into tape recordings or large print.
