Non-Discrimination Policy

Purpose

To prevent agency personnel from discriminating against other personnel or patients/clients on the basis of race, color, religion, ancestry, creed, sex, handicap or place of national origin, citizenship, sexual orientation, martial or familiar status.

Policy

In accordance with Title VI of the Civil Rights Act of 1964 and its implementing regulation, Philadelphia Home Care; Hospice of Philadelphia and its subsidiaries will, directly or through contractual or other arrangement, admit and treat all persons without regard to race, color religion, sex, ancestry, citizenship, sexual orientation, martial or familiar status or 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 and its implementing regulations, Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries will not, directly or through contractual or other arrangements, discriminate on the basis of handicap (mental or physical) in admissions, access, treatment or employment. The Senior Vice President of Home Health and Chief Nurse Officer and the SVP of Hospice has been designated as the coordinators for implementation of this policy in their departments.

In accordance with the Age Discrimination Act of 1975 and its implementing regulation, Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries 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.

Procedure

  1. Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries will identify an organization or person in their service area who can translate for persons with limited English proficiency and who can disseminate information to sensory impaired persons. These contacts will be listed and kept in the departmental policy manual.
  2. The Section 504 Coordinator for Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries will be the Senior Vice President for Home Health and SVP of Hospice of Philadelphia.
  3. The following statement will be printed on brochures and other public materials: "Patient/client services are provided without regard to race, color, creed, age, sex, religion, Ancestry, citizenship, sexual orientation, marital or familiar status, handicap (mental or physical), or place of national origin."

Civil Rights Regional Offices

Human Relations Commission
(215) 560-249		 Harrisburg
Uptown Shopping Plaza
2971-E N. 7th Street
Harrisburg, PA 17110-2123
(717) 787-9784 (Voice)
(717) 787-7279 (TDD)
   
Philadelphia
711 State Office Building
Broad and Spring Garden Streets
Philadelphia, PA 19130-4088
(215) 560-2496 (Voice)
(215) 560-3599 (TDD)		 Pittsburgh
11th Floor State Office Bldg
300 Liberty Avenue
Pittsburgh, PA 15222-1210
(412) 565-5395 (Voice)
(412) 565-5711 (TDD)

Grievance Procedure

It is the policy of Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries not to discriminate on the basis of handicap.

Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries has adopted an internal grievance procedure providing for prompt and equitable resolution of complaint alleging any action prohibited by Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794) or the U.S. Department of Health and Human Services regulations implementing this act. Section 504 states, in part, that "no otherwise qualified handicapped individual shall, solely by reason of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance ..." the law and regulations may be examined in the office of Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries. Senior Vice President for Home Health & the SVP for Hospice of Philadelphia have been designated to coordinate the efforts of to comply with Section 504.

  1. Any person who believes she or he has been subjected to discrimination on the basis of handicap, in contradiction of the policy stated above, may file a grievance under this procedure. It is against the law for Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries to retaliate against anyone who files a grievance or cooperates in the investigation of a grievance.
  2. Grievances for either department must be submitted to the Senior Vice President for Home Health or SVP for Hospice of Philadelphia within thirty (30) days of the date the person filing the grievance becomes aware of the alleged discriminatory action.
  3. A complaint must be in writing, 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.
  4. The Senior Vice President for Home Health or SVP for Hospice of Philadelphia (or her/his patient/client representative) shall 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 Senior Vice President for Home Health and SVP for Hospice of Philadelphia will maintain the files and records of Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries relating to such grievances.
  5. The Senior Vice President for Home Health or SVP for Hospice of Philadelphia will issue a written decision on the grievance no later than thirty (30) days after its filing.
  6. The grievant may appeal the decision of the Senior Vice President for Home Health or SVP for Hospice of Philadelphia by filing an appeal in writing to Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries within fifteen (15) days of receiving the decision.
  7. Philadelphia Home Care or Hospice of Philadelphia shall issue a written decision in response to the appeal no later than thirty (30) days after its filing.
  8. 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 as per attached.
  9. Philadelphia Home Care, Hospice of Philadelphia and its subsidiaries will make appropriate arrangements to assure that disabled persons can participate in or make use of this grievance process on the same basis as the non-disabled. Such arrangements may include, but are not limited to, the provision of interpreters for the deaf, providing taped cassettes of material for the blind, or assuring a barrier-free location for the proceedings. The Senior Vice President for Home Health or the SVP for Hospice of Philadelphia will be responsible for providing such arrangements for their departments.

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