Hanley Foundation Deaf and Hard of Hearing Policy revised 2/2/2016
The purpose of this policy is to establish guidelines for ensuring the provision of services to the deaf and hard-of-hearing customers/consumers who participate in our Substance Abuse Prevention, Level 1 services.
It is the policy of Hanley Foundation (HF) staff to comply with the deaf and hard-of-hearing requirements as defined in the master contract and meet requirements pursuant to Section 504 of the Rehabilitation Act, the Americans with Disabilities Act (ADA) and CFOP 60-10, Ch. 4, “Auxiliary Aids and Services for the Deaf or Hard-of-Hearing.”
Procedures in servicing Deaf and Hard-of-Hearing:
When dealing with a consumer or companion who is Deaf or Hard-of-Hearing, Hanley Foundation (HF) staff shall comply with guidelines set forth in Section 504, ADA and CFOP 60-10 Ch. 4 in regards to making support available to those in need to Auxiliary Aid/Service.
Responsibilities of Hanley Foundation:
All Deaf or 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. Hanley Foundation 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. The Single Point of Contact (SPOC), for Hanley Foundation (HF) is Jan Cairnes, the backup SPOC for the agency is Susan Wheeler.
Duties of the Single Point of Contact for Hanley Foundation:
Single Point-of-Contact duties will include but not be limited to:
· The SPOC will ensure effective communication with deaf or hard- of- hearing consumers and companions, as well as consumers with limited English proficiency.
· HF will ensure that their employees are aware of the requirements, roles, responsibilities, and receive the required training upon hire. HCF will ensure a yearly refresher training on serving deaf or hard-of-hearing consumers and a civil rights training.
· The SPOC will ensure that their auxiliary aids and services plan and auxiliary aids monitoring plan is updated as needed, with any updates received.
Assessing for Communication Needs:
· At the initial point of contact, the SPOC or SPOC backup will be notified immediately. An assessment of communication needs will be conducted for all individuals or companions who are deaf or hard of hearing using the required Florida Department of Children and Families documents. The required documents will be completed 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 to meet the needs of Consumers or Companions who are deaf or hard of hearing.
· HF will at all times recognize that the consumer or companion’s preference is the primary consideration in determining what auxiliary aids or services to provide. If communication through a specific aid or service is deemed to be ineffective, the HF SPOC will assist the consumer or companion in determining a more effective aid or service for communication. Documentation shall be made in the consumer’s file regarding the attempt to improve the effectiveness of auxiliary aids and services. Once the assessment is completed, the SPOC or assigned agency staff shall obtain auxiliary aids according to the communication and request for services assessment.
Provision of Interpreters/Services:
· At no time is it acceptable for staff to deny services to a Consumer without notifying the SPOC. If staff, based on the Communication Assessment results find that auxiliary aids or services are not essential, staff are to contact the SPOC. Additionally, if staff are unsure of how to proceed they are to immediately contact the SPOC at 561-596-3421.
· Staff shall provide interpreters for consumers and companions who are deaf or hard-of-hearing in a timely manner in accordance with the following standards:
o For unscheduled emergency appointments, staff shall make an interpreter available as soon as possible, but in no case later than two (2) hours from the time, the customer or companion or staff requests an interpreter, which ever is earlier. If the situation is not an emergency, staff shall offer to schedule an appointment and provide an interpreter for effective communication at the convenience of the Consumer or Companion, or at least by the next business day.
o For scheduled events, staff shall make a qualified interpreter available at the time of the scheduled appointment. If an interpreter fails to appear for the scheduled appointment, staff shall take whatever additional actions are necessary to make a qualified interpreter available to the consumer or companion who is deaf or hard-of-hearing as soon as possible, but in no case later than two (2) hours after the scheduled appointment. The SPOC shall be notified immediately, in the event a scheduled interpreter fails to appear.
Auxiliary Aids Documentation:
· Staff shall document the Consumer or companion’s preferred method of communication and any requested services provided in the Consumer’s record. Documents and forms evidencing when and how the staff provided aids and services to Consumers or Companions shall be retained in the Consumer’s record for seven years. Forms included but are not limited:
· Consumer or Companion Assessment and assessment Aid and Service Record
· Consumer or Companion Request for Free Communication Assistance or Waiver
· Consumer or Companion Feedback Form
· Consumer Plan (for providing auxiliary aids or services on an ongoing/continuous basis)
· Documentation will be kept for record keeping with the SPOC, and in the Consumer’s record.
· If Consumers or Companions are referred to other agencies, the attending staff and/or SPOC must ensure that the receiving agency is notified of the Consumer or Companion’s preferred method of communication and any auxiliary aid for service needs. In order to accommodate this effectively, the attending staff and/or SPOC will ensure that the referral is approved by the participant and that he or she signs a Release of Information for each referral being made. These actions will be recorded and maintained in the Consumer’s record.
FL DCF Customer Feedback Form:
· The attending staff shall distribute the required Florida DCF Consumer/Companion Feedback form to Consumers or Companions that are deaf or hard- of- hearing and provide assistance in completing the forms if requested by the consumer or Companion. Consumers and Companions shall be instructed to mail the original feedback form to DCF, Office of Civil Rights, 1317 Winewood Boulevard, Building 1, Room 110, Tallahassee, FL 32399-0700, or if requested by the Consumer or Companion; by the SEFBHN SPOC. A copy of the consumer/Companion Feedback Form shall not be kept in the Consumer record/file.
Limited English Proficiency Consumers:
· Staff will provide foreign language interpretation for any Consumer who requests such assistance. HF also has an account with LanguageLine.com
· http://www.languageline.com/solutions/interpretation/ for foreign language interpretation.
Utilize Global Translations and Interpretations of West Palm Beach for interpreters of foreign languages: 800-352-0717, 561-641-3973
· Records relating to auxiliary aids and services provided shall be retained by the SPOC for at least 7 years.
· The SPOC will ensure that conspicuous notices which provide information about the availability of appropriate auxiliary aids and services at no-cost to the deaf or hard-of-hearing Consumers or Companions are posted near Consumer/Companion entrances, and locations where Consumers and Companions receive services. The SPOC’s name and contact information will be available on the Deaf and Hard of Hearing Poster as well the name and contact information for the FL DCF Regional Civil Rights Officer/ ADA 504 Coordinator.
· Approved Notices can be downloaded from The Department’s website.
· The SPOC shall ensure submission of the monthly HHS Report, no later than: The 5the of each month, for the previous month. Submission will be made to HF’s Contract Manager and to the Regional Civil Rights Officer/ADA 504 Coordinator.
· HF shall ensure accessibility to meetings, conferences and seminars to persons with disabilities, limited English proficiency, and those who are deaf or hard- of- hearing. HF will notify the public by placing the following statement on all notices and advertisements prior to the event:
HF will provide accommodations, including American Sign Language interpreters, assistive listening devices, alternative formats of printed materials and real-time captioning upon requests for persons who are deaf, hard of hearing or are living with disabilities. To ensure accommodations, please make your request within 7 days prior to the event to email@example.com
· Staff members shall receive the Florida DCF approved training Service Delivery for the Deaf or Hard-of-Hearing, and a general Civil Rights Training within 60 days of commencing employment. Staff members shall receive an annual refresher training on both, and provided ongoing training as needed on how to use video relay services. Training documentation shall be maintained in each employee’s file.
Auxiliary Aid Services for Deaf and Hard of Hearing Consumers:
· Maintain information on Pocket Talkers and Personal Listening Devices in the office of the SPOC.
· HF does not have access to TDD/TTY equipment but can accept phone calls from individuals who use these items to communicate.
· Ensuring that individuals are aware of and know how to use the Federal Video Remote Interpreting (VRI) and Video Relay Interpreting (also known as the Federal Video Relay service, or VRS) services. The Video Remote Interpreting software can be downloaded at https://www.fedvrs.us.supports/what_is_vri, the phone number is (877) 689-7775, the service is available Monday through Friday from 7am to 11pm EST and English to Spanish Translation is available with 24 hours notice. The Video Relay Interpreting software can be downloaded at www.fedvrs.us, and the service is also available in Spanish. Hanley Foundation does not currently have access to the equipment needed for Video Remote/Relay Interpreting but can accept phone calls from those individuals who use these items to communicate.
Auxiliary Aid Resources:
Florida Relay – 7-1-1
· Through the Florida Relay Service, people who use specialized telephone equipment can communicate with people who use standard telephone equipment. To call Florida Relay, dial7-1-1, or use the appropriate toll-free numbers below:
o Dial 7-1-1 (or the Florida Relay toll-free number appropriate for you specific call listed below)
o A specially trained Florida Relay Operator will answer and identify themselves by their Operator number.
o Give the Operator the phone number of the person you are calling.
o The operator will connect you with the person you are calling and will assist you with communication.
NOTE: If the phone from which you are calling does not accept 7-1-1, we have a list of dedicated toll free numbers for each call-type that you can utilize for the same great service!
o 1-800-955-8771 (TTY)
o 1-800-955-8770 (Voice)
o 1-800-955-3771 (ASCII)
o 1-877-955-8260 (VCO-Direct)
o 1-800-955-5334 (STS)
o 1-877-955-8773 (Spanish)
o 1-877-955-8707 (French Creole)
Language Line – 800-752-6096 or to set up a pay as you need service go to: http://www.languageline.com/solutions/interpretation/personal-interpreter/
Captioning Real Time Resources:
· Captioning (Real Time). This is the simultaneous conversion of spoken words to text, through computer-assisted transcription or court reporting, and displaying that text on a view screen. This communication service is beneficial to individuals who are deaf or hard-of-hearing that do not use sign language or for whom assistive listening devices and systems are ineffective.
· Ensuring that individuals are aware of and know how to use the Captioning in Real Time (CART) Services. CART providers can be found online at http://psl.ncra.org/index.asp. A list of CART providers in Florida is maintained in the office of the SPOC.
· Caption Crew
o Florida Realtime Reporting Services 954-767-0450
110 Broward Blvd # 1850, Fort Lauderdale, FL 33301
o Glenda M. Powers, CRR, RPR, FPR
Powers Certified Realtime Reporting, Inc.
13050 S.W. 6th Court
Davie, Florida 33325 954.829.1758
· If you believe you were wrongfully denied access to services or discriminated against:
o Ask to speak to the HF Compliance Officer or Single Point of Contact immediately.
o You may submit your complaint/grievance in writing and mail it to:
Hanley Foundation, Compliance Officer
Center for Philanthropy
700 South Dixie Highway, Suite 103
West Palm Beach, FL 33401
· Complaints/grievances can also be sent via email to: firstname.lastname@example.org, include the following information in your complaint/grievance:
o What service were you denied?
o What were you told was the reason you were denied service?
o What person denied you services?
o What was the date and time you were denied service?
· Discrimination complaints may also be filed externally with the state and federal government:
o Assistant Staff Director for Civil Rights
1317 Winewood Boulevard, Building1, Room 110
Tallahassee, FL 32399-0700
o Executive Director, Florida Commission on Human Relations
2009 Apalachee Parkway, Suite 100
Tallahassee, FL 32301-4857
o Disability Rights Florida
2473 Care Drive #200, Tallahassee, FL 32308
o US Department of Health & Human Services Office for Civil Rights
Atlanta Federal Center, Suite 3B70 61Forsyth Street, SW
Atlanta, GA 30303-8909
o No person shall, on the basis of race, color, religion, national origin, sex, age, disability, sexual orientation, or gender identity, be excluded from participation in, be denied the benefits of, or be subjected to unlawful discrimination under any program or activity receiving or benefiting from federal financial assistance and administered by HF.
Hanley Foundation’s office hours are from 8am to 5pm EST; there is no 24-hour site available.
If a HF employee is assisting a deaf or Hard-of-hearing customer/companion and is unfamiliar with an auxiliary aid or service requested, the employee may contact the SPOC (or designee), or if the SPOC (or designee) is unavailable, the employee can go to the website or phone number referenced above.
If Hanley Foundation holds a grant funded 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 contracting SPOC Jan Cairnes at 561-268-2355. If you are hearing or speech impaired, please contact the agency using the Florida Relay Service, (800) 955-8771 (TDD) or (800) 955-8770 (Voice).”
A copy of this Policy and Procedure will be posted on Hanley Foundation’s website to be made available to the public for informational purposes for both individuals and organizations. Printed documents (including this Policy and Procedure) 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. HF staff may be required to translate written documents in Braille, taped recording or large print.