ADA Policies/Grievance Procedures
Stepping Stones Counseling Center, PLLC will take appropriate steps to assist with persons with disabilities, including persons who are deaf, hard of hearing, or blind, or who have other sensory or manual impairments, have an equal opportunity to participate in our services, activities, programs, and other benefits.
Services provided by Stepping Stones are client-directed. The service plan responds to a client’s stated needs and is developed in consultation with him/her. Stepping Stones Counseling Center will not refuse to accept a prospective patient or otherwise deny an individual with a disability the opportunity to benefit from its services because of their disability.
Stepping Stones Counseling Center will take appropriate steps to assist persons with disabilities, including persons who are deaf, hard of hearing, or blind, or who have other sensory or manual impairments, in obtaining our services. The procedures outlined below are intended to assist in effective communication with patients/clients and/or the companions of patients/clients involving their medical conditions, treatment, services, and benefits. The procedures also apply to, among other types of communication, communication of information contained in important documents, including waivers of rights, consent to treatment forms, financial and insurance benefits forms, etc.
As active partners in their service, clients have the right to make decisions regarding their well-being, to state their preferences, and to refuse service. Stepping Stones will respect the client’s choice unless there is a concern that the client’s ability to make decisions is impaired and that this decision will result in imminent harm to the client or others.
All staff will be provided written notice of this policy and procedure, and staff that may have direct contact with individuals with disabilities will be trained in effective communication techniques, including the effective use of interpreters. We will also go over all the procedures during our procedure annual meetings. During the training of new employees (within 15 days of hire), this will be gone over in great detail.
This policy applies to all Stepping Stones staff, independent contractors, volunteers, and students.
1. The term “patient” shall be broadly construed to include any individual who is deaf or hard of hearing, or visually impaired, or someone who is seeking or receiving health care services from Stepping Stones Counseling Center at any of its offices or being seen by telehealth.
2. The term “companion” means a person who is deaf or hard of hearing and is either (a) a person whom the patient, consistent with privacy regulations, indicates should communicate with Stepping Stones Counseling Center about the patient, participate in any treatment decision, play a role in communicating the patient’s needs, condition, history or symptoms to Stepping Stones, or help the patient act on the information, advice or instructions provided by Stepping Stones Counseling Center; (b) a person legally authorized to make health care decisions on behalf of a patient; or (c) such other person with whom Stepping Stones Counseling Center would ordinarily and regularly communicate with concerning the patient’s medical condition including, but not limited to, the patient’s next of kin or health care surrogate.
3. The term “auxiliary aids and services” includes qualified interpreters on-site or through video remote interpreting (VRI) services; note-takers; real-time computer-aided transcription services; written materials; exchange of written notes; telephone handset amplifiers; assistive listening devices; assistive listening systems; telephones compatible with hearing aids; closed caption decoders; open and closed captioning, including real-time captioning; voice, text, and video-based telecommunications products and systems, including text telephones (TTYs), videophones, and captioned telephones, or equally effective telecommunications devices; videotext displays; accessible electronic and information technology; or other effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing. 28 C.F.R. §36.303.
4. The term “qualified interpreter” means an interpreter who, via a VRI service or an on-site appearance, is able to interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary. Qualified interpreters include for example, sign language interpreters, oral transliterators, and cued-language transliterators. 28 C.F.R. § 36.104. The qualified interpreter we will be using is Global Interpreter Services. The address is 42633 Garfield Rd. Suite 314 Clinton Township, MI 48038. The form will need to be faxed over to them at FAX (586)580-8345. If you have any questions or concerns you can contact them by email at Interpreter@myterps.com or by phone at (586)778-4188. Attached to this policy is the form to fax over as well. Always fax over the request for an interpreter at least one week in advance when possible, and get a confirmation emailed to us.
1. Clients have the right to state their preference for a service provider within the confines of available resources and the organization’s service approach. Stepping Stones will strive to match client preference to the service provider within reasonable limits.
2. Staff will attempt to maintain connections with hesitant or resistant clients but, at the same time, will respect the wishes of the client.
3. When an individual self-identifies as a person with a disability that affects the ability to communicate or to access or manipulate written materials, or requests an auxiliary aid or service, staff should consult with the individual to determine what aids or services are necessary to provide effective communication. If an individual does not self-identify as a person with a disability, but it is obvious or becomes apparent to staff members that the individual has a disability requiring auxiliary aids and services, staff should inform the patient and/or companion that auxiliary aids and services are available.
4. An alert will be added in Therapynotes (EMR) to notify the providers accessing the medical record of Global Interpreting Services needed by the patient so that it can be scheduled in a timely manner of at least one week in advance.
5. Review and Reassess: Stepping Stones Counseling Center will conduct ongoing assessments of the services being provided to the patient and/or companion at each appointment to assist in providing serves that are effective for communication to the patient and/or companion. If at any time the services being provided are no longer effective, this will be documented in the record and other means of effective communication will be provided. If during any appointment, the therapist feels that the patient should need a higher level of care, such as Psychiatric Services, Case Management, or Inpatient Treatment, to assist with wrap-around services. Stepping Stones Counseling Center will refer the client out to the following facilities:
Macomb Community Mental Health (855) 966-2264
Renewal Counseling Center (586) 783-2950
Dr. Sherr (586)466-5911
Dr. Patelle (586)863-4000
For Inpatient treatment, we will refer to the following facilities:
Harbor Oaks Hospital (586)648-4574
Havenwyck Hospital (248) 373-9200
Stone Crest Hospital 1-866-504-1421
*If we are unable to secure services at these aforementioned agencies/hospitals we will work with the patient to find other resources available in the community. If we decide there is a better-suited option other than the aforenoted agencies/hospitals, the provider will make an individualized decision to best meet patients' needs.
A) Stepping Stones Counseling Center provides notice to patients and/or companions of the availability of and procedure for requesting auxiliary aids and services through written notices contained on Stepping Stones Counseling Center’s Patient Rights and Responsibilities form and on Stepping Stones Counseling Center’s website. In addition, wherever a Patient’s Bill of Rights is required by law to be posted, signs of conspicuous size and print stating, Stepping Stones Counseling Center shall post signs stating:
In compliance with the Americans with Disabilities Act (ADA), qualified interpreters and other auxiliary aids and services are available free of charge to people who are deaf or hard of hearing.
These signs will include the international symbols for “interpreters,” and list the name and contact information of the person(s) to whom a patient or companion should speak in order to request auxiliary aids or services. The signs shall also contain the following statement: “For more information about the Americans with Disabilities Act (ADA) contact the Department of Justice’s toll-free ADA Information Line at 1-800-514-0301 (voice), 1-800-514-0383 (TTY), or visit the ADA Home Page at www.ada.gov.”
B) When an individual self-identifies as a person with a disability that affects the ability to communicate or to access or manipulate written materials, or requests an auxiliary aid or service, staff should consult with the individual to determine what aids or services are necessary to provide effective communication. If an individual does not self-identify as a person with a disability, but it is obvious or becomes apparent to staff members that the individual has a disability requiring auxiliary aids and services, staff should inform the patient and/or companion that auxiliary aids and services are available free of charge. A staff member should consult with the individual with a disability and ask the patient or companion to complete the Communication Assessment form (see attached), assisting the patient or companion as necessary in the process. Stepping Stones Counseling Center staff members will take into account all relevant facts and circumstances, including, but not limited to, the following:
i. The patients’ and/or companions’ request for, or statement of need for, an interpreter or other auxiliary aid or service;
ii. the nature, length, complexity, and importance of the communication at issue;
iii. the individual’s communication skills and knowledge; and the patient’s health status or changes thereto.
Stepping Stones Counseling Center should provide services or aids to achieve effective communication with persons with disabilities.
A) For Persons Who Are Deaf or Hard of Hearing
1. Stepping Stones Counseling Center will provide auxiliary aids and services to patients who are deaf or hard of hearing or who have low vision, and any companions of patients. Note: Stepping Stones Counseling Center will and must provide effective communication, understanding that a live interpreter may be the most effective way to communicate and will be the first priority unless the client requests/prefers other auxiliary aids or services, such as Video Remote Interpreting.
2. Video Remote Interpreting (VRI) – Sign Language - Utilization of VRI via Stepping Stones Counseling Center’s national translation Global Interpreter shall be used for interpretation if a patient prefers and requests this auxiliary aid/service. If there is inclement weather, VRI will be offered. VRI must NOT be used, and an in-person interpreter must be provided if the VRI device is freezing or lagging; the image is not clear (for example, the image is blurry or grainy); the internet connection is slow, inconsistent, or choppy; the VRI device has unclear audio input and/or output; the interpreter’s face and arms cannot be seen at all times; the patient is blind, has low vision, or is otherwise unable to effectively communicate using VRI; the patient is deaf and cannot see the device; an individual’s physical, mental or cognitive impairments prevent the use of VRI to achieve effective communication; staff have any reason to believe the patient is not capable of understanding that the VRI machine provides interpreter services (e.g., young children, mentally ill patients).
3. In-Person Sign-Language Interpreters - If the need for an in-person sign-language interpreter arises, including a request by a patient or a companion who does not wish to use the VRI equipment or a patient requires more than one interpreter, staff will contact Global Interpreter services right away. Some patients/companions who are deaf or hard of hearing may prefer or request to use a family member or friend as an interpreter. However, family members or friends of the person who is deaf or hard of hearing should not be used as interpreters unless specifically requested by that person and after an offer of an interpreter at no charge to the person has been made by the facility. Such an offer and the response should be documented in the medical record. If the person who is deaf or hard of hearing chooses to use a family member or friend as an interpreter, staff should caution the person to be sure they have appropriately considered competency of interpretation, confidentiality, privacy, and potential conflicts of interest. Staff will have the family member or friend sign a Release of Information to comply with HIPPA. If it appears the family member or friend may not be competent or appropriate for any of these reasons, staff should strongly encourage the person to use an in-person interpreter or VRI provided by Stepping Stones Counseling Center.
4. Refusal of Interpretation service - If a patient or companion declines interpretation assistance, the offer and refusal of interpreting services must be clearly documented in the patient’s medical record. It is essential that the person requiring interpreting services specifically indicate their refusal; do not allow another person to refuse on their behalf.
NOTE: Children and other patients will not be used to interpret, in order to ensure confidentiality of information and accurate communication.
B. For Persons who are Blind or Who Have Low Vision
Staff should communicate information contained in written materials concerning treatment, benefits, services, waivers of rights, and consent to treatment forms by reading out loud and explaining these forms to persons who are blind or who have low vision; In addition, staff is available to assist persons who are blind or who have low vision in filling out forms and in otherwise providing information in a written format.
C. For Persons with Manual Impairments
Staff should assist persons who have difficulty in manipulating print materials by holding the materials and turning pages as needed, or by providing other services as needed.
D. For Repeat Patients
If a patient or companion has an ongoing relationship with Stepping Stones Counseling Center, with respect to subsequent visits, staff should continue to provide the appropriate auxiliary aids or services to the patient or companion without requiring a new or subsequent request for the appropriate auxiliary aids or services by the patient or companion for each visit. Staff should document the ongoing provision of auxiliary aids and services to patients and companions in patients’ medical charts. If the aids and services provided at previous visits no longer result in effective communication with the patient or companion, then Stepping Stones Counseling Center shall attempt to reassess the patient to provide different auxiliary aids or services that do result in effective communication.
If the client decides to end service within a session, this decision should be respected. If appropriate, the client should be asked if the counselor can follow up in the future.
When a client drops out of service, cancels, or fails to show up for an appointment, staff will attempt to make direct contact with the client to clarify the situation. This should not be an attempt to persuade the client to return to service but to make it safe for the client to express his/her views and receive validation. This contact should include acceptance of any feedback that the work was not helpful in whole or in part.
If the client no longer wants the service or does not want a particular treatment that has been recommended by the provider, the discussion will be recorded in the client file.
E. Auxiliary Aid and Service Log
Stepping Stones Counseling Center will maintain a log in which requests for auxiliary aids and services, including requests for qualified interpreters (on-site or through video remote devices) will be documented. The log will indicate the time and date the request was made, the name of the patient and the person making the request, the time and date of the scheduled appointment (if a scheduled appointment was made), the nature of the auxiliary aid or service provided, and the time and date the appropriate auxiliary aid or service was provided. If no auxiliary aid or service was provided, the log shall contain a statement concerning why the auxiliary aid and service was not provided.
Stepping Stones Counseling Center has adopted this internal grievance procedure providing for prompt and equitable resolution of complaints alleging any action prohibited by the Americans with Disabilities Act (ADA), which prohibits discrimination against people with disabilities.
For more information about the ADA, call the Department of Justice’s toll-free ADA Information Line at 1-800-514- 0301 (voice), 1-800-514-0383 (TTY), or visit the ADA Home Page at www.ada.gov. Stepping Stones Counseling Center’s Office Administrator, Danielle King is also available to assist at 586-213-1850, or Daniellek@steppingstones-counselingcenter.com to help with any grievances.
Any person who believes she or he has been subjected to discrimination on the basis of disability may file a grievance under this procedure. Stepping Stones Counseling Center will not retaliate against anyone who files a grievance or cooperates in the investigation of a grievance.
- Grievances must be submitted to the Office Administrator within 60 days of the date the person filing the grievance becomes aware of the alleged discriminatory action.
- The complaint must be in writing, containing the name and address of the person filing it. The complaint must state the problem or action alleged to be discriminatory and the remedy or relief sought.
- The Office Administrator (or her/his designee) shall conduct an investigation of the complaint. This investigation may be informal, but it will be thorough, affording all interested persons an opportunity to submit evidence relevant to the complaint. The Office Administrator will maintain the files and records of such grievances.
- The Office Administrator will issue a written decision on the grievance no later than 30 days after its filing.
- The availability and use of this grievance procedure does not prevent a person from filing a complaint of discrimination on the basis of disability with the U.S. Department of Justice or the U.S. Department of Health and Human Services, Office for Civil Rights.
*Stepping Stones Counseling Center will make appropriate arrangements to ensure that disabled persons are provided other accommodations, if needed, to participate in this grievance process. Such arrangements may include but are not limited to, providing interpreters for the deaf or hard of hearing, providing recordings of material for the blind, or assuring a barrier-free location for the proceedings.