Skils’kin’s Compliance Department (QA) continually innovates and regulates the Quality Work Environment (QWE) for all facets of Skils’kin by means of policies, procedures, internal inspections, and quality assurance measures.
The primary purpose of Compliance is to provide assistance throughout the organization by identifying risks prior to accidents or mistakes occurring and to serve as a steadfast source of support should recovery be necessary. We believe transparency is the key to maintaining effective collaboration between our customers, employees, and community stakeholders.
Our team is excited to continue its role in institutionalizing key processes throughout the organization and is pleased to serve as a helping hand and primary resource for employees to examine past experiences, realize present transformations, and help design future solutions.
Cultural Competency and Diversity Plan
Cultural Competency and Diversity Plan
September 1, 2017
Skils’kin celebrates and advances diversity by creating a safe place in which people can express themselves freely and share their unique talents. We believe the diversity of talents enriches our company by fueling creativity, innovation, and success.
What is Cultural Competency?
Cultural competency is an organization’s ability to function effectively while recognizing, respecting and addressing the unique needs, worth, language, thoughts, communications, actions, customs, beliefs and values that reflect an individual’s racial, ethnic, religious, and/or social groups or sexual orientation.
Cultural Competence includes attaining the knowledge, skills, and attitudes to enable administrators and workers within each program to provide effective supports for diverse populations. Our services can only be effective when we utilize knowledge and skills that are culturally competent and compatible with the backgrounds of consumers, their families and communities. Cultural competence acknowledges and incorporates behaviors, beliefs and values in determining an individual’s needs.
Our organization fosters inclusion, tolerance, and respect for diversity in all forms by striving to ensure that we meet the following standards for the population of persons served, employees, families/caregivers, and volunteers. We strive to gather and utilize data-based knowledge from clients, stakeholders, community partners, families and employees.
The goal of cultural competency is to provide the best services in the context of practices that are in line with acceptance, understanding, and open-mindedness toward those whom we serve and work with.
Cultural Competency Standards:
- Acceptance and inclusion that moves beyond simple tolerance to embracing the richness of the diverse identities of our people;
- Promoting cross-cultural awareness and respect.
- Provide respectful and individualized methods of service delivery that embrace the exceptional diversity of our population;
- Assurance that persons served, clients, and families/caregivers receive from all employees and volunteers effective, understandable, and respectful services in a manner compatible with their cultural beliefs and practices in their preferred language.
- Implement strategies to recruit, retain, and promote at all levels a diverse staff and leadership representative of the demographic characteristics of our area;
- Hire employees who are representative of our persons served in an effort to provide settings that promote comfort, trust, and familiarity;
- Maintain a current demographic, cultural, and epidemiological profile of the community as well as a needs assessment to accurately plan for a services that respond to the cultural characteristics of our area;
- Recognize that cultural issues are not limited just to ethnicity considerations, but may also include age, gender, sexual orientation, spiritual beliefs, socioeconomic status, language and other issues;
- Value differences including cultural differences and recognize similarities among consumers, employees, families/caregivers, volunteers, customers and vendors;
- Support a work environment free of all forms of discrimination, including sexual, religious or cultural harassment;
- Ensure that conflict and grievance resolution processes are culturally sensitive and capable of identifying, preventing, and resolving cross-cultural conflicts or complaints by persons served and clientele;
- Skils’kin strives to be proactive in our training, education, and service delivery. We conduct annual cultural diversity/competency training (diversity training);
- Encourage a climate of cooperation and collaboration in ALL work environments that promotes a positive attitude toward our provision of services;
Cultural Competency Plan
Authority, Structure, and Responsibility for the Integration and Implementation of the Plan
The Skils’kin Risk Management Team has the authority and responsibility to integrate cultural competency throughout Skils’kin. Within the Risk Management Team the Compliance Manager will develop and provide oversight of the plan.
The Risk Management Team is charged with implementing the Cultural Competency Plan. The Plan is required to be reviewed annually. The Cultural Competency Plan will be briefed to the RMT twice a year during regularly scheduled RMT meetings to review progress toward meeting plan goals, to plan new initiatives, and to provide resources and technical assistance to others.
The overall aim of the plan is to foster a culturally competent staff by:
- Recognizing and honoring diversity in all forms;
- Assessing cultural competency;
- Offering continuous, comprehensive cultural competency/diversity education and training for staff
- Promoting the recruitment of bilingual/bicultural staff
Skils’kin’s overall strategy has been, and will continue to be the following continuous looping sequence: (1) assess the extent to which Skils’kin is meeting the needs of the culturally diverse populations we serve, (2) plan the necessary steps and interventions needed to address and deficiencies noted in the assessment and to build on the strengths identified, (3) implements the plans developed, and (4) evaluate effects of the implementation.
If we are unable to meet the cultural needs of an individual, every effort will be made to provide appropriate referrals and be available for follow-up.
Overall Goal of the Cultural Competency Program
To confront the problem of the disparities and barriers to service that exist across the many different aspects of “culture,” including, language, ethnicity/race, religion, sexual orientation, sex/gender roles, socioeconomic status, and age, a Cultural Competency Plan has been developed that define our expectations with respect to providing culturally proficient services. The Skils’kin plan will include:
- Gathering feedback (via surveys, suggestion boxes, website feedback);
- Development of specific goals (see below);
- Specific strategies to meet those goals; and
- Measures to the extent to which the goals are met
Skils’kin values differences and recognizes similarities among consumers, employees, families/caregivers, volunteers, customers and vendors. It is the responsibility of all Skils’kin employees and volunteers to generate and maintain work environments in which everyone feels respected, valued and welcomed.
Culturally Competent Goals
Goal: Ensure persons served and clients are receiving culturally appropriate services.
- Impact of culture is incorporated into the service planning process through a variety of methods.
- Recruitment of bilingual/bicultural staff.
- Cultural Competency/diversity training for staff.
- Audits; consumer satisfaction surveys.
- Staff are required to participate in ongoing diversity training
Goal: Ensure persons served and clients receive linguistically appropriate services
- Utilization of language translation services or computer applications
- Client materials are easily understood and available in language choice
- Annual review of demographics
- Client materials and signage are reviewed annually
- Language application available on website. Selectable in multiple languages.
- Provide the following language services:
- Alternative formats
- Translation Services (Through the County upon request)
- Large Print documents
- Braille (Services available through DSB)
- Narration of any document by staff
Goal: Ensure persons served and clients have access to services that are sensitive to their cultural needs.
- Organizational assessment
- Knowledge of service area demographics
- Provide relevant trainings to staff
- Annual review of progress toward its goals, grievances, and accessibility assessments
- RMT briefing twice annually during scheduled meetings to review demographics and action items.
Corporate Compliance Notice
Skils’kin is committed to the delivery of services in an environment characterized by the highest standards of accountability for administrative, program/employment, business, marketing, and financial management services. Further, the management of Skils’kin is fully committed to the prevention and detection of fraud, waste, abuse, fiscal mismanagement and misappropriation of funds and has developed a corporate compliance program that emphasizes (1) prevention of wrong doing – whether intentional or unintentional, (2) immediate reporting and investigation of questionable activities and practices without consequences to the reporting party and (3) timely correction of any situation which could potentially put its consumers, stakeholders, the organization, its leadership or employees at risk.
Any person wishing to submit a report of any suspected case of waste, fraud, abuse or wrongdoing can do so confidentially and without fear of retaliation or reprisal. Reports can be submitted in person or by mail, telephone or e-mail to the organization’s Corporate Compliance Officer:
Director of Human Resources
4004 East Boone Avenue
Spokane, WA 99202-4509
June 14, 2016
Company Rights and Responsibilities
The following is an excerpt from our Company Rights and Responsibilities Policy:
Responsibilities – All Employees
- Skils’kin recognizes that our employees are essential to successful performance of our mission, and that out strengths lie in putting everyone’s good ideas to work. The basic virtues of kindness, courtesy, and integrity are among the elements that provide an environment conducive to mission performance and a pleasant working environment.
- Employee Responsibilities to Persons Served:
- People with disabilities, their families, friends and allies teach us much about the importance and value of listening to and being guided by the very people who “experience” the services and supports that we provide. Therefore:
- All people have the right to be treated with dignity and respect.
- All people have the right to access services which allow them to achieve their highest individual potential.
- All people have the right to make their own choices and direct their own lives.
- All people have the right to develop meaningful relationships with people they care about and who care about them.
- All people should be able to feel good about themselves and have others recognize them for what they contribute to others and to the community.
- All people have the right to be involved—to be active in the community and to do the things they enjoy.
- All people should be able to learn to do things on their own or to be supported to do things for themselves.
- All people should be able to feel safe and to enjoy good health.
- Supports must consider individuals’ cultural/ethnic backgrounds and preferences.
- All employees must:
- Ensure that individual rights are recognized and protected.
- Place the needs of persons served over personal and other agency needs.
- Guard against any form of exploitation.
- Ensure that services are provided in the least restrictive and most integrated manner.
- Advocate change in existing services in a professional manner.
- Respect the confidentiality of persons served.
- Employee Responsibilities to Customers:
- Comply with all contractual obligations.
- Respect customers and treat each one objectively, honestly, and fairly.
- Maintain open communication.
- Promote trust.
- Work cooperatively and promote teamwork with all customers or stakeholders (persons served, clients, contractors, coworkers and other agencies).
- Perform quality, timely work for all customers, staff members and clients.
- Respond promptly and positively to any concerns regarding our products or services.
- Employee Responsibilities to Community:
- Promote public awareness of the rights and capabilities of citizens with disabilities.
- Positively reflect the agency and its goals to the community.
- Disclosures of reports and documents are in full, fair, accurate, timely and understandable.
- Employee Responsibilities to Skils’kin:
- Follow all policies and procedures.
- Work safely.
- Observe rules and procedures developed for the safe operation of machines, tools and equipment, and practice safe working methods.
- Report all safety hazards and violations.
- Dress appropriately for position, and consistent with internal policy, safety, and health regulations.
- Efficiently manage one’s time.
- Keep personal telephone calls and visits to a minimum.
- Do not engage in outside business or social activities while on duty.
- Maintain accurate information.
- Maintain equipment and protect property.
- Use the greatest care when using equipment, vehicles, supplies, grounds or materials.
- Report maintenance and repair problems to Supervisors.
- Skils’kin property should only be used for agency purposes.
- Participate in the employee suggestion/request system. Suggestions for improvement are always appreciated.
- Be open to new ideas.
- Seek continued growth through continuing education.
- Maintain membership and participate in professional organizations.
- People with disabilities, their families, friends and allies teach us much about the importance and value of listening to and being guided by the very people who “experience” the services and supports that we provide. Therefore:
Grievance Resolution Procedure
This is an excerpt of Skils’kin’s Grievance Resolution Procedure.
Skils’kin believes performance complaints are best resolved at the lowest level possible. We have a six-step grievance resolution procedure that allows for grievances/complaints to be resolved in a timely manner with fair negotiation and resolution.
Skils’kin strives to ensure the health and safety of all individuals receiving services. If the complaint poses a major health and safety concern, we may not adhere to all steps described in the grievance resolution process.
This procedure applies to all individuals and staff in the Employment, Community Living Services (CLS) and Payee Services departments; the Corporate Compliance Officer (CCO) or designated Human Resources (HR) Representative/Advocate; CEO; and the Board of Directors (BOD).
CLS, Employment, Payee Department Directors/Managers, and the CCO must each maintain a grievance log. These logs are treated as confidential documents. Access is limited to the CCO, CEO, Board of Directors, Compliance Manager, and others on a “need to know” basis.
- Grievances consist of individual complaints regarding quality of service that have not been resolved informally at a lower level.
- Grievance logs must include department, the issue reported, individuals affected, and resolution/results of investigations. They must note any open complaints.
The CCO logs all formal grievances/complaints that pertain to compliance issues.
- The Compliance Manager reviews this log with the CCO on a quarterly basis to verify investigations and concur in the findings.
- Additionally, the Compliance Manager is included on all investigation correspondence in real time and conducts interviews (randomly) to verify fair and just handling of the case.
- A copy will be provided to the CEO, Board of Directors, and others as required by contract and/or Mandatory Reporting Policy.
Under Skils’kin’s reporting policy, Skils’kin prohibits retaliation or harassment against anyone filing a truthful report or assisting in a corporate investigation. Concerns regarding retaliation or harassment should be reported to the CEO or CCO. Any person who retaliates against an employee or other person will be subject to discipline, up to and including termination.
Accused employees are protected by the False Claims Act. If an investigation finds that an employee has knowingly or willfully fabricated information on a report, or has knowingly or willfully distorted, exaggerated, or minimized information, disciplinary action may be taken against the employee, up to and including termination.
- Procedure for CLS Department: see Attachment 1
- Procedure for Payee Services Department: see Attachment 2
- Procedure for Employment Services Department: see Attachment 3
- This policy and its attachments are included in the Individual Employment Handbook. All individuals are expected to read and/or understand this policy prior to receiving services with Skils’kin.
- If an individual does not respond to the findings of a complaint within the specified time frames, the matter will be closed.
- We encourage individuals to use our Human Resources department to assist them through the grievance process.
- Individuals involved with a grievance and/or active investigation are discouraged from discussing the matter with others not directly involved in the resolution process. Employees are prohibited from this activity.
- For issues that involve multiple individuals, each individual must file a complaint for their individual grievance to be addressed.
- If the grievance is with Skils’kin’s CEO, it must be submitted in writing to the HR Director, who then submits the complaint directly to the Board of Directors.
- The Board of Director’s decision shall be provided to the individual in writing within thirty (30) business days.
Skils’kin Accessibility Plan
1.1. To establish methods to ensure that Skils’kin develops, administers and maintains an Accessibility Plan that addresses accessibility and barriers that adversely affect:
1.1.1. Quality of life for persons served.
1.1.2. Discriminatory employment practices.
1.1.3. Legal and regulatory requirements.
1.1.4. Expectations of Skils’kin Stakeholders.
2.1. Applies to all employees, contractors and/or volunteers providing services to persons served.
3.1. Board of Directors and President/CEO
3.1.1. Ensure that resources are provided to ensure compliance with this Policy.
3.2. Compliance Manager
3.2.1. Serve as Administrator for the Accessibility Plan.
3.2.2. Train appropriate Directors and Managers on the Accessibility Plan.
3.2.3. Oversee Stakeholder Surveys.
3.2.4. Serve as Chairperson on the Risk Management Team.
3.2.5. Conduct an annual review of Accessibility Plan(s) (Attachment 1) received.
3.3. Director of Human Resources
3.3.1. Ensures that training on how to request accommodations is provided at time of hire and periodically thereafter.
3.4. Directors and Managers
3.4.1. Provide training on the Accessibility Plan to employees and persons served.
3.4.2. Ensure that persons served under their direction are aware of their right to request accommodations and to identify barriers.
3.4.3. Provide and document annual Disability Awareness training for employees under their direction.
4.1. Accessibility – Addresses a barrier, or lack thereof, for persons with disabilities to obtain services.
4.2. Barrier – A physical, cognitive, sensory, emotional, or developmental condition that obstructs or inhibits the ability for a person with a disability to obtain services.
5.1. Risk Management Team (RMT)
5.1.1. The RMT will be comprised of one member from each department providing services to persons with disabilities.
5.1.2. Semi-annual meetings will include a review/discussion of the following:
22.214.171.124. Requests for accommodations that were received during the past six months.
126.96.36.199. Barriers that were identified and/or corrected.
188.8.131.52. Training opportunities for staff or persons served.
184.108.40.206. Review of in-process Access Plans and those currently submitted. Refer to Section 5.3.3.
220.127.116.11. Recommendations or suggestions for improving accessibility or removing barriers.
5.1.3. The RMT will develop and communicate to stakeholders via the Annual Performance Target Report information on accommodations and/or barriers that were identified during the year and what actions were taken to remedy them.
5.2.1. Physical Barriers
18.104.22.168. Buildings that Skils’kin owns or controls access to will comply with the Americans with Disabilities Act (ADA).
22.214.171.124. An annual inspection will be facilitated and conducted by the Compliance Department, using the ADA Self-Inspection Checklist. A Corrective Action plan will be developed on items indicated as “non-compliant.”
5.2.2. Environmental Barriers
126.96.36.199. During the ADA survey, inspectors evaluate if any of our locations or settings compromise, hinder, or impede delivery of service. The following will be considered:
188.8.131.52.1. Excess noise
184.108.40.206.2. Poor lighting
220.127.116.11.3. Excess traffic
18.104.22.168.4. Fragrances or odors
5.2.3. Attitudinal Barriers
22.214.171.124. We will address attitudinal barriers in our Accessibility Surveys and in global trainings by:
126.96.36.199.1. Using terminology that is used to describe persons with disabilities.
188.8.131.52.2. Ensuring that persons with disabilities are treated with respect and viewed as valuable members of the Skils’kin team.
184.108.40.206.3. Seeking and utilizing input from persons served.
220.127.116.11.4. Evaluating if there are eligibility barriers for certain types of disabilities.
5.2.4. Financial Barriers
18.104.22.168. Assess whether we provide sufficient funding and resources to support the services we provide.
22.214.171.124. Assess our need and willingness to offer the following:
126.96.36.199.1. Flex time
188.8.131.52.2. Job sharing
184.108.40.206.3. Part-time work
220.127.116.11. Assess our use of, or need to, incorporate the following:
18.104.22.168.1. Voice recognition technology
22.214.171.124.2. Teletype machine (TTY)
126.96.36.199.3. A user-friendly website
188.8.131.52.3.1. Input from stakeholders on access issues related to our website
184.108.40.206. Assess whether persons with disabilities can easily reach the locations where service is provided.
5.2.8. Community Integration
220.127.116.11. Assess whether there are barriers that prevent involvement in community activities.
5.3. Identifying Barriers
5.3.1. Consult with persons with disabilities who are knowledgeable in accessibility and accommodations to determine methods, equipment, or accommodations that could be incorporated into our services
5.3.2. Compliance will develop an Accessibility Checklist that includes physical, program, employment and communication barriers.
18.104.22.168. The Checklist may reference the ADA Self-Assessment Checklist.
5.3.3. Compliance will develop an Access Plan to address the following (Attachment 1):
22.214.171.124. How to identify barriers
126.96.36.199. Possible solution(s) to barriers
188.8.131.52. A priority for the barrier
184.108.40.206. Estimated cost to eliminate or minimize the barrier
220.127.116.11. Estimated completion date
18.104.22.168. Person responsible for the project
5.3.4. Train Directors, Managers, Supervisors and appropriate personnel on Sections 5.1-5.3 of this Policy
5.4. Evaluating the Accessibility Plan
5.4.1. The Accessibility Plan will be reviewed semi-annually by the RMT. These reviews will consist of the following:
22.214.171.124. Completed Access Plans
126.96.36.199. Progress of open or ongoing Access Plans
188.8.131.52. Suggestions submitted by staff, employees or stakeholders
184.108.40.206. Trainings conducted
220.127.116.11. Any issues that might impede the removal of barriers
5.4.2. The fall meeting will consist of items listed above with the addition of:
18.104.22.168. Funding recommendations, if any, for the upcoming fiscal year
22.214.171.124. A review of the draft Performance Target Report that includes:
126.96.36.199.1. Barriers eliminated or minimized during the year
188.8.131.52.2. Barriers that still present a challenge
184.108.40.206.3. Opportunities and recommendations for improvement in the upcoming year
6.1. Attachment 1, Accessibility Plan (available through SpiceWorks)
7.1. Americans with Disabilities Act (ADA)
7.2. CARF International Standard, Section 1.L, Accessibility
7.3. Skils’kin Employee Handbook
7.4. Accessibility Self-Assessment Checklists
8.1. New Policy developed by Quality Assurance on 09/29/2014.
8.1. Revised and released by Compliance Manager on 09/15/2016.
8.1. Reviewed and revised by Compliance Department. Released on 4/13/2017.
Ethical Code of Conduct Overview
The purpose of Skils’kin’s Ethical Code of Conduct is to provide guidance and set common ethical standards for our employees and officers to adhere to on a consistent basis.
OUR MISSION: To enrich the quality of life for adults with disabilities.
OUR VALUES: Accountability, Collaboration, Diversity, Innovation and Integrity
It is Skils’kin policy to conduct our business affairs in an ethical, impartial, honest and proper manner. Self-interests and personal desires will not interfere with teamwork or fairness.
Skils’kin understand the importance of its human resources; this is why we are committed to maintaining a professional and diverse workforce.
When marketing services and products to the public, Skils’kin employees will be transparent, honest, and respectful. In promoting our services or products be respectful to employees, clients and individuals including their cultural beliefs and values. We will protect confidential information and respect the privacy of our employees and participants.
Illegal and Unethical Acts
Our commitment to integrity begins with complying with laws, regulations, and rules where we do business. Skils’kin employees follow an internal Fraud and Abuse Policy and are required to report fraud, bribery, theft, falsification of records and other wrongdoing. Good Faith reports of illegal or unethical acts will be kept anonymous, if desired, and can be made without fear of retaliation.
Conflicts of Interest
All Skils’kin employees must avoid situations that create a conflict of interest or the appearance of one. Our employees understand that these conflicts might compromise our integrity and reputation.
Gifts and Money
Skils’kin employees are strongly discouraged from accepting gifts from salespeople, vendors, suppliers or any other type of solicitor. Furthermore, giving or receiving expensive and/or meaningful gifts, to or from program participants, is not appropriate in the professional environment, even with the best of intentions.
We understand that in any professional relationship there is an innate power imbalance that arises. Our clients and individuals trust our staff to be professional and act with their best intentions in mind. Skils’kin staff must ensure that as advocates we encourage and assist our participants in building and maintaining healthy boundaries.
Selling and Solicitation
No non-employee is allowed to come on to the property of Skils’kin to survey, petition or distribute literature to employees. In addition, Skils’kin employees may not solicit for any purpose, at any time, in any work area during working time.
In the spirit of open communication, Skils’kin employees are encouraged to ask questions and to get advice from their supervisor, the Human Resource Department, the Compliance Manager or the CEO.
It is the responsibility of each Skils’kin employee to act in an ethical, fair and impartial manner in all interactions with our clients, individuals, community and customers. It is the responsibility of each employee to respond promptly and positively to any concerns with our products or services. Each employee has the responsibility to promote Skils’kin and protect its assets. Each employee has the responsibility to advocate for people with disabilities and promote public awareness of the rights and capabilities of people with disabilities.
The policies and procedures listed on this page were last updated 7/3/2017.