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 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. The overall aim of the plan is to foster a culturally competent culture and services within Skils’kin.
What is Cultural Competency?
Cultural competency is our organization’s awareness, recognition and inclusion of the unique needs, worth, thoughts, communications, actions, customs, beliefs and values that reflect our employee’s and client’s dynamic qualities, beliefs and contributions.
Cultural Competence includes attaining the knowledge, skills, and attitudes to enable Skils’kin’s culture and services to supports the diverse populations we serve and employ. When culturally competent knowledge and skills are utilized, our employees, our clients, their families and our communities benefit. Cultural competence acknowledges and incorporates behaviors, beliefs and values in determining an individual’s needs.
Skils’kin fosters inclusion and respect for diversity in all forms by striving to ensure that we meet the following standards. We strive to gather and utilize data-based knowledge from clients, stakeholders, community partners, families and employees.
Cultural Competency Standards:
- Acceptance and inclusion that moves beyond simple tolerance to embracing the richness of the diverse identities of all people;
- Promoting cross-cultural awareness and respect;
- Provide respectful and individualized methods of service delivery that embrace the exceptional diversity of our clients;
- Assurance that clients, and their families/caregivers receive effective, understandable, and respectful services in a manner compatible with their cultural beliefs and electronic translations in their preferred language (upon request);
- 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 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, ability and other issues;
- Value differences and recognize similarities among clients, their families/caregivers, employees, volunteers, customers and vendors;
- Support a work environment free of all forms of discrimination;
- Ensure that conflict and grievance resolution processes are culturally sensitive and capable of identifying, preventing, and resolving cross-cultural conflicts or complaints by all;
- 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 and respect;
- It is the responsibility of all to generate and maintain work environments in which everyone feels respected, valued and welcomed.
Cultural Competency Plan
Responsibility for the Implementation of the Plan
The Skils’kin Risk Management Team has the authority and responsibility to integrate Cultural Competency Plan throughout Skils’kin. Within the Risk Management Team the Director of Quality and Compliance will develop and provide oversight of the plan.
The Skils’kin plan follows a cyclical feedback mechanism:
- Annual survey to all Skils’kin stakeholders specific to Skils’kin’s achievement of the standards above;
- Provide other means of feedback, such as suggestion boxes and website
- Compile annual client and employee demographics
- Compile and analyze feedback results, and communicate to appropriate leadership
- Compare annual demographics to current demographic, cultural, and epidemiological profile of the community
- Develop strategies to address areas of opportunity whenever possible
- If we are unable to meet the cultural needs of a client, every effort will be made to provide appropriate referrals and be available for follow-up.
- Provide training, tools, resources, service delivery changes to meet areas of opportunity
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
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 our 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 for a pleasant working environment.
Employee duty 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 should feel safe.
- Supports must consider individuals’ cultural/ethnic backgrounds and preferences.
- All employees must:
- Ensure that individual rights are recognized and protected.
- Consider 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.
- 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).
- Respond promptly and positively to any concerns regarding our products or services.
- Promote public awareness of the rights and capabilities of persons served, clients/individuals.
- Positively reflect the agency and its goals to the community.
- Follow all policies and procedures.
- Work safely.
Employee Responsibilities to Customers:
Employee Responsibilities to Community:
Employee Responsibilities to Skils’kin:
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 procedure.
- This procedure applies to all Skils’kin Staff, with specific procedures for Employment and Payee Services departments.
- This provides guidance to the Corporate Compliance Officer (CCO), CEO, and the Board of Directors (BOD).
Vice Presidents and Managers: Make this procedure available, and to explain it to all staff members and individuals so they have a clear understanding.
It is the responsibility of these department Directors/Managers, their department staff, the CCO (or designated HR Representative), CEO, and the Board of Directors to manage grievances consistently. Skils’kin may provide an external mediator for unresolved conflicts.
The CCO, Vice President of State Programs and Director of Payee Services must each maintain a grievance log. These logs are confidential documents. Access is limited to the CCO, CEO, BOD, Director of Compliance (DOQ), 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, reported issue, affected individuals, and resolution/results of investigations. They must note any open complaints.
The CCO logs all formal grievances/complaints that pertain to compliance issues.
- The CM reviews this log with the CCO on a quarterly basis to verify investigations and concur in the findings.
- The CM 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, BOD, and others as required by the contract and/or Mandatory 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 CCO or CEO. Anyone 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.
- 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 Human Resources to assist with 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 people, each person 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 (CCO), who then submits the complaint directly to the BOD.
- The Board of Director’s decision shall be provided to the individual in writing within thirty (30) business days.
Accessibility Request Form
Skils’kin Accessibility Plan
To establish methods to ensure that Skils’kin develops, administers and maintains an Accessibility Plan that addresses accessibility and barriers that adversely affect:
Applies to all employees, contractors and/or volunteers providing services to persons served.
Board of Directors and President/CEO
Director of Quality and Compliance
Vice President of Human Resources
Accessibility – Addresses a barrier, or lack thereof, for persons with disabilities to obtain services.
Barrier – A physical, cognitive, sensory, emotional, or developmental condition that obstructs or inhibits the ability for a person with a disability to obtain services.
Risk Management Team (RMT)
The RMT will be comprised of one member from each department providing services to persons with disabilities. Periodic meetings will include a review/discussion of the following:
Compliance will develop and communicate to the RMT information on accommodations and/or barriers that were identified during the year and what actions were taken to remedy them.
- Physical Barriers
- Buildings that Skils’kin owns or controls access to will comply with the Americans with Disabilities Act (ADA).
- 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.”
- Environmental Barriers
- 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:
- Excess noise
- Poor lighting
- Excess traffic
- Fragrances or odors
- Attitudinal Barriers
- We will address attitudinal barriers in our Accessibility questions on various surveys and in global trainings by:
- Using terminology that is used to describe persons with disabilities.
- Ensuring that persons with disabilities are treated with respect and viewed as valuable members of the Skils’kin team.
- Seeking and utilizing input from persons served.
- Evaluating if there are eligibility barriers for certain types of disabilities.
- Financial Barriers
- Assess whether we provide sufficient funding and resources to support the services we provide.
- Assess our need and willingness to offer the following:
- Flex time
- Job sharing
- Part-time work
- Assess our use of, or need to, incorporate the following:
- Voice recognition technology
- Teletype machine (TTY)
- A user-friendly website
- Transportation Barriers
- Assess whether persons with disabilities can easily reach the locations where service is provided.
- Community Integration
- Assess whether there are barriers that prevent involvement in community activities.
- Compliance will develop an Accessibility Checklist that includes physical, program, employment and communication barriers.
- The Checklist may reference the ADA Self-Assessment Checklist.
- Compliance will develop an Accessibility Request to address the following (Attachment 1):
- How to identify barriers
- Possible solution(s) to barriers
- A priority for the barrier
- Estimated cost to eliminate or minimize the barrier
- Estimated completion date
- Person responsible for the project
- Compliance will train Vice Presidents, Directors, Managers, Supervisors and appropriate personnel.
- Completed Accessibility Requests
- Review of Accessibility question responses on various surveys
- Progress of open or ongoing Access Plans
- Suggestions submitted by staff, employees or stakeholders
- Any issues that might impede the removal of barriers
- Funding recommendations, if any, for the upcoming fiscal year
- Americans with Disabilities Act (ADA)
- CARF International Standard, Section 1.L, Accessibility
- Skils’kin Employee Handbook
- Accessibility Self-Assessment Checklists
Identifying Barriers– 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.
Evaluating the Accessibility Plan– The Accessibility Plan will be reviewed annually by the RMT. These reviews will consist of the following:
Attachment 1, Accessibility Plan (available through SpiceWorks)
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.