Nondiscrimination Policy and Grievance Process
Purpose
To prevent organization personnel from discriminating against other personnel, patients, or other organizations on the basis of race, color, religion, age, sex (an individual’s sex, gender identity, sex stereotyping, pregnancy, childbirth and related conditions), sexual orientation, disability (mental or physical), communicable disease, or national origin.
Policy
In accordance with Title VI of the Civil Rights Act of 1964, Section 1157 of the Affordable Care Act (ACA) of 2024 and its implementing regulation, Episcopal Homes of Minnesota 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, Section 1557 of the Affordable Care Act (ACA) of 2024 and its implementing regulations, Episcopal Homes of Minnesota will not, directly or through contractual or other arrangements, discriminate on the basis of disability (mental or physical) in admissions, access, treatment or employment.
In accordance with the Age Discrimination Act of 1975, Section 1557 of the Affordable Care Act (ACA) of 2024 and its implementing regulation, Episcopal Homes of Minnesota 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, Episcopal Homes of Minnesota 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.
Procedure
- The Section 504/ADA Compliance Coordinator designated to coordinate the efforts of Episcopal Homes of Minnesota to comply with the regulations will be the Chief Administrative Officer. Contact the Compliance Coordinator at 651-272-4910.
- Episcopal Homes of Minnesota will identify an organization or person in their 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.
- A copy of this policy will be posted on the Episcopal Homes of Minnesota website, given to each organization staff member, and sent to each referral source upon request.
- The following statement will be posted in the reception of the organization in English and at least the top 15 non-English languages spoken in the state: “Patient services are provided without regard to race, color, religion, age, sex (an individual’s sex, gender identity, sex stereotyping, pregnancy, childbirth and related conditions), sexual orientation, disability (mental or physical), communicable disease, or national origin.”
- The following statement will be printed in English and other non-English languages spoken in the state on appropriate printed public materials and in a conspicuous location on the organization’s web site accessible from the home page: “Patient services are provided without regard to race, color, religion, age, sex (an individual’s sex, gender identity, sex stereotyping, pregnancy, childbirth and related conditions) , sexual orientation, disability (mental or physical), communicable disease, or national origin.”
- Any person who believes she or he 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 Episcopal Homes of Minnesota 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 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 Episcopal Homes of Minnesota within 15 days of receiving the Section 504 Coordinator’s decision.
- Episcopal Homes of Minnesota 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 Episcopal Homes of Minnesota 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.
- Episcopal Homes of Minnesota will make appropriate arrangements to assure 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 will 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.
Job title of policy owner: Chief Administrative Officer – Episcopal Homes of Minnesota
Approval date: 5/1/2025