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CULTURAL COMPETENCY & NON-DISCRIMINATION TRAINING

Promoting Excellence

Through Training

2018

Overview

Learning Objectives

DentaQuest does not discriminate against members, providers or

employees on the basis of race, color, birthplace, language, sex, religion,

beliefs, age, sexual orientation or disability.

The purpose of this training is to provide instruction on the federal and

state regulations which prohibit discrimination in programs and activities

that are funded by federal and state dollars.

This training is not legal advice and does not cover every issue related to

civil rights compliance. You should consult an attorney about your specific

circumstances and obligations.

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Commitment to a Diverse and Inclusive Culture

DentaQuest is committed to a culture that is diverse and inclusive.

Discrimination is a direct action, whether purposeful or not, that results in

unequal treatment of people. It is not allowed due to a Person’s:

• Race, Color, or National Origin (Title VI of the Civil Rights Act of 1964 and T.

C. A. § 4-21-904)

• Disability (Section 504 of the Rehabilitation Act of 1973 and Americans with

Disabilities Act of 1990)

• Sex and Blindness/Visual Impairment (Title IX Education Amendments of

1972)

• Age (Age Discrimination Act of 1975)

• Race, Color, National Origin, Age, Disability, Sex, Gender Identity, Failure

to Conform to Stereotypical Notions of Masculinity or Femininity, and

Sexual Harassment based on Sexual Orientation (Section 1557 of the

Affordable Care Act)

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Two Different Forms of Discrimination:

1. Intentional (Disparate Treatment) Discrimination:

Persons who are from the same group are treated differently than people

who are not from that group. The different treatment was motivated by an

intent to discriminate.

2. Disparate Impact (Effects) Discrimination:

A procedure or practice has a disparate (unequal) impact on protected

individuals and the procedure or practice lacks a legitimate reason

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Understanding Member and Provider Rights

• A person who is a beneficiary (TennCare member) or a participant

(TennCare provider) in a program that receives federal funds cannot be

denied services or benefits, simply because of his or her:

o Race,

o Color,

o National Origin,

o Disability,

o Sex, Age, or

o Other Protected Status

• A person can be denied benefits and/or services if they do not meet the

eligibility requirements. This is not unlawful or a form of discrimination

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Understanding Member and Provider Rights

(cont.)

Because of a Person’s Race, Color, National Origin, Disability, Sex, Age, Creed,

Religion, Gender Identity, Failure to Conform to Stereotypical Notions of

Masculinity or Femininity, and Sexual Harassment based on Sexual Orientation

Status

He or She CANNOT:

• Be denied or delayed any service, aid or other benefit

• Be subjected to segregation or unequal treatment in a TennCare/CoverKids program.

• Be given services in humiliating or embarrassing ways

• Be provided services using different rules to decide who will get help

• Be limited in the use of buildings, rooms or other space in a way that denies them

participation or access

• Be denied access to a service because buildings or facilities are not physically accessible

to those with disabilities or because there was no means of effective communication with

TennCare/CoverKids, the service provider, or DentaQuest

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Unequal Health Care

Affects racial and ethnic minorities and other underserved populations

(gender status, sexual orientation, disability status)

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What does Unequal Health Care Look Like?

• A patient who uses a wheelchair is examined by a doctor in the

wheelchair because the patient could not get on the exam table

What should the doctor do to avoid this situation?

• Obtain accessible equipment, such as, an adjustable exam table and/or

a ceiling or floor based patient lift; and

• Train staff on proper patient handling techniques to provide equal

medical services to a patient with a disability

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Cultural Competency

DentaQuest works to decrease discrimination by focusing on Cultural Competency in Health Care.

“Cultural Competency” in Health Care is defined as: effective integration and transformation of knowledge about groups and individuals into specific standards, policies, practices and attitudes which can be implemented into appropriate settings to increase the quality of health care, thereby producing better health outcomes for all.

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Cultural Competency (cont.)

Cultural competency is rooted in mutual respect, validation and

openness towards someone with different social and cultural perceptions

and expectations than your own. This means DentaQuest employees must

be:

• Knowledgeable about cultural differences and their impact on health beliefs,

practices, and behavior on the part of the member, DentaQuest staff, and the

provider;

• Sensitive, understanding, non-judgmental, and respectful in dealings with

people whose cultures are different from your own; and

• Flexible and skillful in responding and adapting to different cultural contexts and

circumstances.

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DentaQuest Works to Ensure Cultural

Competency by:

1. Ensuring that members receive effective, understandable, and

respectful care.

2. Implementing strategies to recruit, retain, and promote a diverse staff

that represent the demographics of the service area at all levels of the

organization.

3. Ensuring that staff receive training in culturally and linguistically

appropriate service delivery.

4. Offering and providing language assistance services at no extra

charge to members.

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DentaQuest Works to Ensure Cultural

Competency by:

5. Providing written notices to members in their preferred language.

6. Assuring the competence of language assistance by utilizing

interpreters and bilingual staff. This enables DentaQuest to:

• Ensure complete, accurate, impartial, and confidential communication;

and

• Avoid family, friends or other relatives serving as interpreters.

7. Ensuring that appeal, complaint and grievance resolution processes

are culturally and linguistically sensitive in an effort to identify, prevent,

and resolve cross-cultural conflicts or complaints by members.

8. Ensuring diversity and suitability of the DentaQuest provider network.

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Strategies for Cultural Interactions

When working with those whose beliefs, standards and codes of behavior

are different, consider the following:

• Respect all members as individuals, then as members of a minority status and

of a specific ethnic group.

• Never assume that a person’s ethnic identity tells you anything about his or her

cultural values or patterns of behavior.

• Treat all “facts” you have heard or read about cultural values and traits as

hypotheses, to be tested anew with each member.

o Turn facts into questions.

• Listen with empathy and care for what the member is saying.

o Explain your perception of the problem or question to make sure that you

both are understanding the situation the same way.

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Definitions You Need to Know:

Racial Discrimination: treating a person or group of people differently

based on their racial origins.

• For racial discrimination to occur, power is a necessary precondition;

and

• Racial discrimination depends on the ability to give or withhold

social benefits, facilities, services, opportunities etc., from someone

who should be entitled to them, and are denied on the basis of race,

color or national origin.

Limited English Proficiency (LEP): the inability to speak, read, write, or

understand the English language at a level that permits an individual to

interact effectively with staff in accessing public services and benefits.

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Additional Definitions You Need to Know:

Prejudice: a pre-formed opinion, usually an unfavorable one, based on

insufficient knowledge, irrational feelings, or inaccurate stereotypes

• Prejudice can be prejudgment for or against an individual, a group

or an object; and

• Synonyms of prejudice: narrow-mindedness, intolerance,

unfairness.

Discrimination: treatment that favors one individual, group or objective

over another.

Racism: any action or attitude, conscious or unconscious, that

subordinates an individual or group based on skin color or race.

• Racism can be enacted individually (by single individuals) or

institutionally (by all members of an institution).

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Additional Definitions You Need to Know:

Disability:

• A physical or mental impairment that substantially limits one or more

major life activities of a person;

• A person’s record of having an impairment; or

• Being regarded as having an impairment

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Title VI of The Civil Rights Act of 1964

• States are subject to Title VI of the Civil Rights Act of 1964 as both a

Federal and a State Law. Title VI prohibits discrimination on the basis

of race, color or national origin in programs or activities that receive

federal financial assistance.

• Eligible Medicaid members cannot be denied assistance because of

race, color or national origin.

• Entities receiving financial assistance shall not do any of the following

based on protected status:

o Deny an individual a service, aid or other benefit.

o Provide a benefit, etc. that is different or is provided in a different manner.

o Subject an individual to segregation or separate treatment.

o Restrict an individual in the enjoyment of benefits, privileges, etc.

o Treat an individual differently when determining eligibility.

o Select sites or locations of facilities that exclude protected individuals.

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The Rehabilitation Act of 1973

Section 504 of The Rehabilitation Act of 1973 is a Federal Law that

protects qualified individuals from discrimination based on their disabilities.

These nondiscrimination requirements apply to employers and

organizations that receive financial assistance from any federal

department or agency.

Section 504:

• Forbids organizations and employers from excluding or denying

individuals with disabilities an equal opportunity to receive program

benefits and services.

• Defines the rights of individuals with disabilities to participate in,

and have access to, program benefits and services.

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Title II of The ADA

Title II of The Americans with Disabilities Act, as amended (ADA)

provides comprehensive civil rights protections and prohibits

discrimination on the basis of disability in the services, programs or

activities of all state and local governments.

Disability is defined as a physical or mental impairment that substantially

limits a person’s major life activities.

• “Physical and Mental Impairment," includes, but is not limited to, visual,

speech and hearing impairments, mental retardation, emotional illness,

specific learning disabilities, cerebral palsy, epilepsy, muscular

dystrophy, multiple sclerosis, orthopedic conditions, cancer, heart

disease, diabetes, and contagious and non-contagious diseases such

as tuberculosis, and HIV diseases (whether symptomatic or

asymptomatic).

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DO:

• Provide services, programs

and activities in an integrated

setting.

• Make reasonable changes to

policies, practices and

procedures to avoid

discrimination on the basis of

disability.

• Provide auxiliary aids to

individuals with disabilities

(e.g., qualified interpreters,

materials in Braille).

DON’T:

• Refuse to allow a person with

a disability to participate in or

benefit from services,

programs or activities.

• Provide services to

individuals with disabilities

through programs that are

separate or different unless

the programs ensure the

benefits and services are

equally effective.

Do’s & Don’ts for Compliance with ADA

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DentaQuest & Limited English Proficiency

DentaQuest provides information in a culturally competent manner to all

individuals, including those with LEP or reading skills, and diverse

cultural and ethnic backgrounds.

• All vital documents requiring a beneficiary’s signature must be interpreted

in full detail or a translated version must be supplied;

• DentaQuest has bilingual staff in departments that have direct contact with

members (e.g. Spanish, Creole, Mandarin); and

• DentaQuest maintains access to the Certified Language Line to provide

quality service to members who have LEP in additional languages.

All providers must be made aware that all language services are at no

cost to all DentaQuest members.

The TennCare Program, CoverKids Program, and other Markets require

that DentaQuest monitor and ensure compliance with all Title VI

requirements.

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If you need to use an interpreter during an interaction

with a TennCare or CoverKids member:

• Don’t say anything that you do not want interpreted.

• Speak slowly, clearly and in a normal tone of voice.

• Ask one question at a time.

• Speak in short simple sentences, pausing to permit the interpretation.

• Use simple words to express your meaning.

• Allow the person doing the interpreting to stop you and seek clarification

when necessary.

• Look for signs of comprehension, confusion, agreement, or disagreement

from the person you are communicating with.

• Be prepared to repeat yourself in different words if your message is not

understood.

• If you suspect that your message is not fully understood by either the person

doing the interpreting or the person you are communicating with, double

check to see if she/he understands.

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Communication System Requirements

It is important to note that Communication Systems must be provided for free to members who are protected under Section 504 of The Rehabilitation Act of 1973 as well as The American with Disabilities Act of 1990.

This includes members who are blind, visually impaired, and/or deaf.

Examples of accommodations include:

• Interpreters;

• Braille materials;

• Large print documents; and

• TTY/TDD phone lines.

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Auxiliary Aids

(ADA, Section 504, Section 1557)

Individuals with disabilities may need auxiliary aids and services in order to effectively communication with others.

A few common forms of auxiliary aids or services are:

Large print materials/documents, handwritten notes,

telecommunication relay service calls, and qualified interpreters.

Qualified interpreters are able to interpret effectively, accurately, and impartially using any necessary specialized vocabulary, such as, medical terms needs for effective American sign language communication

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Providing Auxiliary Aids or Services

• In order to provide equal access to TennCare & CoverKids programs’ services and benefits auxiliary aids and services are required to be provided when necessary to ensure effective communication. The next several slides contain guidance on the provision of auxiliary aids or services.

• The type of auxiliary aid or service needed to effectively communicate with a person will depend on the person you need to communicate with;

• The reason for, the length of, and complexity of the communication involved; and

• The situation in which the communication is taking place

• ** Remember: The type of auxiliary aid or service needed can change during a conversation or service encounter

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Providing Auxiliary Aids or Services

• In order to be effective, auxiliary aids and services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability

For Example:

• A hospital emergency room must be able to communicate with patients about symptoms and patients must be able to understand information provided about their conditions and treatment. In this situation, an interpreter is likely to be necessary for communications with individuals who are deaf.

• ***Remember this is an interactive process with the individual who needs/is requesting an auxiliary aid or service. In determining what if any types of auxiliary aids and services are necessary, give primary consideration to the requests of the individuals with disabilities.

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Telecommunications Relay Service

You may receive a Telecommunications Relay Service (“TRS”) call from an individual with a disability.

A TRS call is also known as a relay call. TRS is a telephone service that allows persons with hearing or speech disabilities to place and receive telephone calls. Relay calls use operators often called communications assistants to assist with the calls.

Further information and instructions about how to make and receive TRS calls can be provided by the Federal Communications Commission at:

http://www.fcc.gov/guides/telecommunications-relay-service-trs

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Auxiliary Aids

(ADA, Section 504, Section 1557)

Individuals with disabilities may need auxiliary aids and services in order to effectively communication with others.

A few common forms of auxiliary aids or services are:

Large print materials/documents, handwritten notes,

telecommunication relay service calls, and qualified interpreters.

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Sensitive Use of Language Guidelines

It is DentaQuest’s practice to follow specific sensitive

language guidelines when speaking to members.

Examples of implementing this practice include:

• Avoid referring to a disability unless it is relevant;

• Avoid sensationalizing a disability by saying, “a victim of,” “afflicted with,”

etc. Instead say something like “a person who has…”;

• Avoid emotional descriptions. For example, say “uses a wheelchair” rather

than “confined to a wheelchair”;

• Avoid labeling and grouping people as "the disabled," "a paraplegic,” etc.

Instead say, “people with disabilities,” or “a person who has paraplegia.”

(Note that words “disabled,” “blind,” and “deaf,” are adjectives, not nouns);

and

• Do not assume that a person with a speech impediment has some sort of

mental limitation.

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Sensitive Use of Language Guidelines

Avoid portraying successful people with disabilities as remarkable,

superhuman, or inspirational. This implies that it is unusual for people

with disabilities to have talents or skills.

Avoid the word “special” in regard to a disability, as in “special entrance”

or “special transportation.” Instead, say “accessible entrance” and “lift-

equipped buses.” The word “special” serves to segregate rather than

integrate people with disabilities.

Avoid using an over-familiar tone in referring to people with disabilities.

A person with a disability deserves the same courtesy of address and

references as a non-disabled person. A person with a disability, for

example, is often referred to or addressed on a first name basis when

their non-disabled peers in similar contests would not be.

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The Age Discrimination Act of 1975

The Age Discrimination Act of 1975 is a Federal law that prohibits

discrimination on the basis of age in programs and activities receiving

federal financial assistance.

The Act does allow for certain exceptions or waivers that permit, under

limited circumstances, use of age distinctions. For example: Federal

and local governments can enact statutes which provide benefits for

target groups in age-related terms.

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Federal Health Care Conscience Protection

Statutes

Federal regulations require that no entity receiving funds provided by the

U.S. Department of Health and Human Services may require to perform or

assist in performing health services, health research, or health education

if that activity would be contrary to the practitioner’s religious beliefs or

moral convictions.

The statutory requirements are found in the Federal Health Care Conscience

Protection Statutes:

• The Public Health Service (PHS) Act Sec. 245 (42 U.S.C. 238n);

• The Weldon Amendment (Consolidated Appropriations Act 2008, Public

Law 110-161, Div. G, Sec. 508 (d), 121 Stat. 1844, 2209); and

• The Church Amendments (42 U.S.C. 300a-7).

DentaQuest policy of non-discrimination includes compliance with these

provisions in recruiting, selecting, and maintaining providers to participate in our

networks and render services to our members.

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Health Care Literacy

DentaQuest is committed to supporting Health Care Literacy for all

members

Literacy is defined as a person’s ability to read, write, speak and

compute and solve problems at levels necessary to:

• Function on the job and in society;

• Achieve one’s goals; and

• Develop one’s knowledge and potential.

The term illiteracy means being unable to read and write. A person who

has limited or low literacy skills is not illiterate.

Health care literacy is the degree to which individuals have the capacity

to obtain, process and understand basic health information and services

needed to make appropriate health decisions.

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Health Care Literacy

Health care literacy affects an individual’s ability to:

• Navigate the healthcare system;

• Independently complete necessary documents relevant to their care (e.g.,

permission to release personal health information);

• Locate providers and services;

• Share personal information, such as health history, with providers;

• Engage in self-care (i.e. adhering to instructions for prescription and over

the counter drugs) and adhere to treatment plans for acute situations and

chronic-disease management; and

• Understand mathematical concepts that are applicable to probability and

risk as related to incidence of disease and prognosis of outcomes of

medical treatment plans.

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Sexual Harassment

Sexual Harassment is not allowed in the TennCare and CoverKids Programs

• Sexual harassment occurs in the speech or conduct of individuals and does not occur exclusively between persons of the opposite sex. Sexual harassment also occurs between individuals of the same gender.

There are 3 main forms of sexual harassment:

1) Quid-Pro-Quo Sexual Harassment

2) Hostile Environment Sexual Harassment

3) Third Party Sexual Harassment

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Quid-Pro-Quo Sexual Harassment

Quid-Pro-Quo sexual harassment is defined as any unwelcome sexual advance, request for sexual favors, or other verbal or physical conduct of a sexual nature, when:

• (1) Submission to or rejection of such conduct is made, either explicitly or implicitly, a term or condition of an individual receiving a TennCare or CoverKids service or benefit.

• (2) Submission to or rejection of such conduct is used as a basis for decisions affecting the individual who is the victim of the harassment.

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Hostile Environment Sexual Harassment

• This form of sexual harassment is deliberate, unwelcome, or repeated offensive comments, gestures, and/or physical contact of a sexual nature, that is imposed on individuals in the place or environment where the receive his/her TennCare or CoverKids services or benefits. A hostile or offensive environment is also defined as certain pictures, posters, or graffiti that is located or found in the environment.

• Examples of the types of conduct that could constitute sexual harassment are: use of obscene word(s) or language; deliberate touching of another person in a sexual manner; requesting dates from employees; telling off color jokes; displaying pictures of nudes or nearly nude individuals or of individuals in suggestive poses; and displaying or distributing writings or clippings from periodicals that contain such pictures or words.

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Third Party Sexual Harassment

• This form of sexual harassment, more commonly known as "sexual favoritism," is when employment opportunities or benefits are granted to an individual for submitting to a supervisor's sexual advances or requests for sexual favors. Managers can be held liable for unlawful sex discrimination against qualified individuals who were denied an employment opportunity or benefits in cases where sexual favoritism by the manager is determined to have occurred.

For example:

• A resident in a graduate medical program could be subject to this form of discrimination

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Tennessee Civil Rights Laws

T. C. A. § 4-21-101 et seq. safeguards all individuals within the state from discrimination because of race, creed, color, religion, sex, age or national origin in connection with employment and public accommodations.

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When Discrimination Occurs

All members and providers have the right to file a complaint if they feel

they have been subjected to or witnessed violations of the following

acts:

• Title VI of the Civil Rights Act of 1964;

• Section 504 of The Rehabilitation Act of 1973; and

• The Americans with Disabilities Act of 1990.

DentaQuest is required to provide a public notice of the right to file a

complaint, have available a complaint form to provide a complainant, as

well as instructions on how to file a complaint.

The DentaQuest Non-Discrimination Notice can be found here:

http://www.dentaquest.com/nondiscrimination-notice/.

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Anti-Harassment & Discrimination (cont.)

Harassment can consist of a single incident or a pattern of behavior

where the purpose or effect is to create a hostile, offensive or

intimidating work environment which substantially interferes with the

work performance.

Forms of Harassment: • Physical or mental abuse;

• Racial, ethnic or religious slurs or jokes;

• Use of threatening, intimidating, coercive or abusive language,

inappropriate joking and/or gestures; and

• Display and/or distribution of posters, electronic communication, written

material, cartoons or drawings derogatory to a person’s race, sex, sexual

orientation, religion, age, disability or ethnic background.

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Self-review your conduct:

To determine if your conduct is appropriate, ask yourself the following

questions:

• Would I want my conduct to be the subject of a column in the newspaper or

to appear on the evening news?

• Is there equal power between me and the person I am interacting with?

• Would I behave the same way if the person that I’m in a relationship with

were standing next to me?

• Is there equal initiation and participation between me and the person I’m

interacting with?

• Would I want someone else to act this way toward a person that I’m in a

relationship with?

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Reasonable Accommodation/Modification

Under the ADA, Section 504, and Section 1557:

• An individual with a disability may need a reasonable

accommodation/modification in order to be able to receive a service or

benefit or otherwise participate in the TennCare or CoverKids programs

This means your organization may need to make reasonable changes to

policies, practices and procedures to avoid discrimination on the basis of

disability

• The TennCare and CoverKids programs do not have to provide an

individual’s proposed reasonable accommodation if it would fundamentally

alter the service, program, or activity or would result in undue financial and

administrative burdens

28 C.F.R. § 35.130 and 28 C.F.R. § 35.164

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What is a Reasonable Accommodation?

A requested accommodation must be:

1) Linked to the person’s disability-related needs;

2) Necessary to afford an equal opportunity to enjoy the services or

benefits; and

3) Possible to implement

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Recognizing an Accommodation Request

When working with an individual here are some key words and phrases

that will alert you to a possible request:

• Reasonable accommodation

• Discrimination

• Treated differently or denied a service or help due to disability

• Rights are being violated

• ADA

• Disability (“I need help because of my disability”)

• “I am having a problem that is related to my medical condition.”

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Recognizing an Accommodation Request

Remember: The person does not have to say or ask for reasonable

accommodation but you will:

• Need enough information from the person to know about the

disability and desire for an accommodation (help or assistance);

• The circumstances must cause you to ask about the need for an

accommodation (help or assistance)

When a person makes a reasonable accommodation request tell

DentaQuest’s Nondiscrimination Compliance Coordinator:

Ugonna Onyekwu, Regulatory Compliance Associate.

(617) 886-1683 or fairtreatment@dentaquest.com

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TennCare and CoverKids Reporting

Discrimination

It is DentaQuest’s responsibility to report all discrimination complaints to the

appropriate TennCare or CoverKids program and to assist TennCare and

CoverKids with the investigation of the complaints when requested.

• DentaQuest must provide assistance to TennCare members with filing

complaints when language assistance is needed and/or communication

assistance in an alternative format at no charge.

The Non-discrimination Compliance Coordinator will maintain the following

information for all member, provider, or sub-contractor related discrimination

complaints:

• Name of complainant;

• Complainant’s relationship to the Company;

• Circumstances of complaint;

• Date complaint filed; and

• Name of responsible person for resolution and adjudication of the

complaint.

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TennCare and CoverKids Reporting

Discrimination

All complaints of discrimination should be forwarded to DentaQuest’s Non-

discrimination Compliance Coordinator, Ugonna Onyekwu, Regulatory

Compliance Associate.

Each complaint received is monitored for non-compliance with the following:

• Title VI of the Civil Rights Act of 1964;

• Section 504 of The Rehabilitation Act of 1973;

• The Americans with Disabilities Act of 1990; and

• The Age Discrimination Act of 1975.

Complainants are advised in writing of their right to have their complaint

reviewed by the U.S. Department of Health and Human Services or the Office

for Civil Rights, Region IV if they are not satisfied with determination made by

the appropriate TennCare or CoverKids Program.

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TennCare and CoverKids Reporting

Discrimination

All complaints of discrimination should be forwarded to DentaQuest’s Non-

discrimination Compliance Coordinator:

Ugonna Onyekwu, Regulatory Compliance Associate

• (617) 886-1683

• fairtreatment@dentaquest.com

Or to

TennCare/CoverKids Office of Civil Rights Compliance

• 310 Great Circle Road; Floor 3W • Nashville, TN 37243

• 615-507-6474 or for free at 855-857-1673 (TRS 711)

• HCFA.fairtreatment@tn.gov

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TennCare and Coverkids Complaints – HOW TO

FILE REPORT

• You or someone on your behalf may file a complaint if you think you have

been treated differently because of your race, color, birthplace,

disability/handicap, age, sex, religion or any other group protected by law.

• Complaints must be reported within 6 months from the date you think you

were treated differently. The deadline can be increased if there is a good

reason for the delay in reporting the complaint to TennCare (e.g., serious

illness, death in the family, etc.)

• A complaint may be reported electronically by using the complaint forms

found at the DentaQuest website, or in writing. These forms are provided in

English and Spanish

• You must include in the report:

o Your name, address and telephone number, and your signature;

o Name and address or program you think treated you differently

o How, why, and when you think you were treated differently.

o Any other important information

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TennCare and CoverKids Complaints -

Investigation

DentaQuest investigates all TennCare and CoverKids complaints of

discrimination within the following framework:

• Thirty (30) days for investigation and resolution upon receipt;

• Contact made with the complainant and respondent;

• Documentation is reviewed by appropriate TennCare or CoverKids program for validity of discrimination and a determination is made;

• The complainant is notified in writing of the determination and steps taken to resolve the issue; and

• Complainants are advised in writing of their right to have their complaint reviewed by the U.S. Department of Health and Human Services or the Office for Civil Rights, Region IV if they are not satisfied with determination made by the appropriate TennCare or CoverKids program.

All complaints are reported quarterly to the TennCare and CoverKids.

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Additional Reporting Options

Individuals who feel they have been discriminated against may also

contact the following to report:

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Party Phone

Number Email (if applicable)

DentaQuest Non-discrimination

Compliance Coordinator,

Ugonna Onyekwu

(617) 886-1683 fairtreatment@dentaquest.com

U.S. Dept. of Health & Human

Services – Office of Civil Rights

(800) 368-1019

U.S. Dept. of Health & Human

Services – Region VI

(404) 562-7886

Tennessee Bureau of TennCare

and CoverKids, Office of Civil

Rights Compliance

(615) 313-4748

Tennessee Human Rights

Commission

(800) 251-3589

Resources

For additional questions or information on the DentaQuest Non-

Discrimination program (TennCare, CoverKids, and non-Tennessee

programs), please contact DentaQuest’s Non-Discrimination

Compliance Coordinator, Ugonna Onyekwu:

• By Phone: (617) 886-1683

• By Email: fairtreatment@dentaquest.com

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Resources

For LEP information:

• Limited English Proficiency Federal Website: http://www.lep.gov/

• Tennessee Foreign Language Institute: http://tfli.org/

• For ADA information: http://www.ada.gov/

For other civil rights resources:

• HHS, Office of Civil Rights: http://www.hhs.gov/ocr/office/index.html

• U.S. Department of Justice, Civil Rights Division:

http://www.justice.gov/crt/

• United States Department of Health and Human Services Office of

Minority Health:

http://www.minorityhealth.hhs.gov/

Promoting Excellence Through Training

Attestation

Thank you for completing this training and doing your part to prevent,

identify, and correct discrimination.

Please access and complete the required attestation which can be

located: https://www.surveymonkey.com/r/P3NQ37H. If you have any

questions, please contact your provider representative.

Promoting Excellence Through Training