Summer 2000 OCR UPdate - 14
University of Illinois HMO, Chicago, Illinois (Region V)
OCR Region V completed a full scope compliance review of the University of Illinois Health Maintenance Organization (HMO) with significant corrective action secured. The issues in this review were, whether the recipient: (1) assures that hearing-impaired persons have access to a full range of auxiliary aids, including qualified interpreters; (2) ensures effective communication with limited English proficient (LEP) persons so that they have access to its administrative services, marketing and enrollment information/forms, program information, educational classes and medical services; (3) discriminates on the basis of age in the enrollment process; and (4) employs marketing practices that have the effect of denying information and/or enrollment opportunities to LEP persons. OCR cited the recipient for several violations of Section 504, the Americans with Disabilities Act, and Title VI. However, we found the recipient in compliance with the Age Discrimination Act.
During the investigation, interviews with staff indicated that it was standard practice to use family members and friends to interpret for hearing impaired and LEP clients. The recipient also failed to provide notice of its obligation to offer auxiliary aids and interpretation services to hearing impaired and LEP clients. Further, the recipient did not have policies and/or procedures in place to address the provision of services to these clients.
Subsequent to OCR's providing technical assistance, the recipient developed a plan containing policies and procedures which addressed the provision of auxiliary aids and interpretation services for hearing impaired and LEP members and prospective members. The plan includes procedures for effective communication in certain situations, such as doctor office visits, diagnostic and lab services, visits to specialists, health education classes, etc. For hearing-impaired members, the plan describes communication aids (e.g., TDDs, telephone flashers, closed caption television, flash cards, and paper and pencil) that are available and how to use them appropriately. Regarding LEP members, the plan includes information on the availability of qualified on-site interpreters, bilingual staff, access to the AT&T Language Line, and interpreters provided by the Patient Access Program through the University. All services are to be provided as needed, at no cost to the member.
The recipient corrected all areas of deficiency, and we therefore found it in compliance with the civil rights laws. The University of Illinois HMO provides services to over 6,000 members, and has a provider network of nine hospitals and over 300 primary care physicians. Its new plan to enhance services to hearing impaired and LEP clients will have a far-reaching effect.
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