Goodskin Dermatology complies with all applicable federal civil rights laws, including Section 1557 of the Affordable Care Act (Section 1557). Goodskin Dermatology does not discriminate on the basis of race, color, national origin (including limited English proficiency and primary language), age, disability, or sex, including sex characteristics, including intersex traits; pregnancy or related conditions; sexual orientation; gender identity, and sex stereotypes.

In compliance with Section 1557 and other federal civil rights laws, we provide individuals the following in a timely manner and free of charge:

• Language Assistance Services: Goodskin Dermatology will provide language assistance services for individuals with limited English proficiency (including individuals’ companions with limited English proficiency) to ensure meaningful access to our programs, activities, services, and other benefits. Language assistance services may include:
  • Electronic and written translated documents
  • Qualified interpreters
• Appropriate Auxiliary Aids and Services: Goodskin Dermatology will provide appropriate auxiliary aids and services for individuals with disabilities (including individuals’ companions with disabilities) to ensure effective communication. Appropriate auxiliary aids and services may include:
  • Qualified interpreters, including American Sign Language interpreters
  • Video remote interpreting
  • Information in alternate formats (including but not limited to large print, recorded audio, and accessible electronic formats)
• Reasonable Modifications: Goodskin Dermatology will provide reasonable modifications for qualified individuals with disabilities, when necessary to ensure accessibility and equal opportunity to participate in our programs, activities, services, or other benefits.

To access our language assistance services, auxiliary aids and services, and for assistance in getting a reasonable modification, please refer to Goodskin Dermatology Language Access procedures, Effective Communication procedures, and Reasonable Modification procedures. For additional assistance, you may also contact Compliance Officer for Goodskin Dermatology at compliance@goodskinmd.com

If you believe Goodskin Dermatology has failed to provide these services or has discriminated in another way on the basis of race, color, national origin, sex, age, or disability, you can:

1. File a grievance with Compliance Officer.
2. File a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights:

Electronically: https://ocrportal.hhs.gov/ocr/smartscreen/main.jsf

Via mail:

U.S. Department of Health & Human Services
200 Independence Avenue, S.W. – 509F
Washington, D.C. 2020

• English
• Español
• Français
• Deutsch
• 日本語
• 한국인
• Tiếng Việt
• Русский
• українська

REASONABLE MODIFICATION PROCEDURES:

In accordance with Section 1557 of the Affordable Care Act, this document serves as Goodskin Dermatology reasonable modification procedures designed to ensure that qualified individuals with disabilities may obtain reasonable modifications when appropriate. Qualified individuals with disabilities may, at any time, request that Goodskin Dermatology reasonably modify, change, except, or adjust a rule, policy, practice, or service when necessary, so that Goodskin Dermatology does not unlawfully deny the individual equal access to our programs, activities, services, and other benefits.

Goodskin Dermatology reasonable modifications for qualified individuals with disabilities may include, but are not limited to: assisting an individual perform a task; allowing an individual to perform a task with assistance, or in another way, time, or place; and modifying non-essential program requirements.

Reasonable modifications that are provided to an individual when they first contact Goodskin Dermatology should again be made available to that individual if the individual returns to Goodskin Dermatology, unless the individual confirms that they no longer require the same modification.

1. REQUESTS FOR REASONABLE MODIFICATIONS

If an individual affirmatively requests a reasonable modification to access our programs, activities, services, or other benefits, staff will provide the modification to the individual if the requested modification does not result in a fundamental alteration to our program or activity. Staff will contact clinic manager in a timely manner to help determine whether Goodskin Dermatology can provide the requested reasonable modification. Staff will document the request in the individual’s record.

Goodskin Dermatology accepts written and verbal requests for reasonable modifications. Individuals are not required to use the term “reasonable modification” when making a request. The individual’s modification request must describe the needed modification and explain how it is related to their disability unless these things are apparent or otherwise known. The decision to provide a specific reasonable modification to a qualified individual with a disability shall be made on a case-by-case basis in a timely manner after evaluating the relevant facts.

When Goodskin Dermatology receives a reasonable modification request, Goodskin Dermatology will immediately provide the requested modification, if feasible. If Goodskin Dermatology cannot provide the requested reasonable modification immediately upon request, and if Goodskin Dermatology receives the request in advance of the individual’s need for the modification, Goodskin Dermatology will acknowledge receipt of the request in writing no later than 10 business days from receipt of the request.

When Goodskin Dermatology receives a reasonable modification request, including when Goodskin Dermatology receives the request at the point of service, Goodskin Dermatology will initiate an interactive, good faith dialogue with the requestor to assess the request. In most cases the individual with a disability will know best what type of modification will meet their needs. When the disability and type of modification needed are obvious, there is no need to have that dialogue.

Goodskin Dermatology may ask for documentation when the disability or need for modification is not obvious. If the disability is visually apparent or otherwise known, and if the requested modification does not appear related to the disability, Goodskin Dermatology may request additional information from the individual necessary to evaluate the disability-related need for the modification.If neither the disability nor the relationship between the disability and the requested modification is clear, Goodskin Dermatology may ask the individual for proof of both. Goodskin Dermatology will review and consider, as appropriate, documentation from an individual’s doctor or other medical professional, a peer support group, a non-medical service agency, or a reliable third party who is in a position to know about the individual’s disability and need for the requested modification.

When additional information is necessary, Goodskin Dermatology will notify the requestor about what information is needed and offer a reasonable time for the requester to provide the information to us. If, after a reasonable period of time, the requestor fails to provide the necessary information, the decision about the request will be based upon the information available to Goodskin dermatology. If necessary, Goodskin Dermatology will inform the requestor of the opportunity to submit another modification request with more information.

If a Goodskin Dermatology staff member is unable to immediately provide an individual with a disability their requested reasonable modification, the staff member will so advise the individual and forward the request to clinic manager to evaluate whether the requested modification will fundamentally alter the nature of the program, activity, service, or other benefit at issue. If the requested modification would result in a fundamental alteration, we will provide a written explanation of how the requested modification will alter the program, activity, service at issue. We will also decide if there is another modification that can be provided that would not result in a fundamental alteration.

For reasonable modification requests that Goodskin Dermatology staff members cannot provide immediately, including at the point of service, barring extenuating circumstances, we will make a final decision regarding our provision of the modification within ten business days of the request, and we will communicate the decision via telephone or text, and in writing, to the requestor.

Goodskin Dermatology staff will document the outcome of our decision to grant or deny the individual the requested modification in the individual’s record.

2. OBSERVABLE LIKELY NEED FOR A REASONABLE MODIFICATION

If an individual’s disability is apparent or otherwise known, Goodskin dermatology staff should ask the individual if they need a reasonable modification to have meaningful access to our programs, activities, services, and other benefits, and staff will initiate the interactive evaluation process described in Section 1 above.

3. STAFF TRAINING

Goodskin dermatology will ensure that all relevant staff are trained on the procedures for granting reasonable modifications as set forth in this document.

EFFECTIVE COMMUNICATION PROCEDURES:

Goodskin Dermatology will take appropriate steps to ensure that communications with individuals with disabilities, including persons who are deaf, hard of hearing, blind, have low vision, or who have other sensory or manual disabilities, are as effective as communications with others. The procedures outlined below are intended to ensure Goodskin Dermatology staff effectively communicate with individuals (including companions with disabilities) regarding their medical conditions, treatment, and participation or potential participation in our programs, activities, services, and other benefits.

These procedures also apply to, among other types of communication, verbal or written communication of important information, including information contained in documents such as waivers of rights, consent to treatment forms, financial and insurance benefits forms, etc. Goodskin Dermatology shall furnish appropriate auxiliary aids and services, where they are necessary, to allow individuals with disabilities an equal opportunity to participate in and benefit from our programs, activities, services, and other benefits.

When auxiliary aids and services are necessary for an equal opportunity to participate and benefit, they will be provided in a timely manner without cost to the individual(s) being served. Auxiliary aids and services include, but are not limited to, qualified interpreters, large print materials, acquisition or modification of equipment or devices, or other similar services or actions.

Goodskin Dermatology is not required to take any action that would result in a fundamental alteration in the nature of the health program and activity or undue financial and administrative burdens.

Goodskin Dermatology shall take appropriate steps to ensure that staff who may have direct contact with individuals with disabilities effectively communicate with individuals with disabilities, including through the effective use of interpreters and other appropriate auxiliary aids or services.

1. IDENTIFICATION AND ASSESSMENT OF NEED:

Goodskin Dermatology staff members must identify individuals with disabilities who need appropriate auxiliary aids and services to communicate with individuals with disabilities effectively.

Goodskin Dermatology staff may identify individuals with disabilities through observation, inquiries to the individuals, and/or by consulting an individual’s existing medical record to see whether it indicates the individual has a disability and needs auxiliary aids or services to ensure effective communication. Individuals with disabilities may self-identify their need for effective communication via appropriate auxiliary aids and services. Staff will consult with the individual to determine what auxiliary aids and services may be necessary to communicate with them effectively.

Staff will document the individual’s preferred auxiliary aid or service in the individual’s record, including any auxiliary aids and services necessary to communicate with companions, and such documentation will identify the individual’s or their companion’s preferred auxiliary aids and services, the actual aids and services provided if different from preferred aids and services.

2. PROVISION OF AUXILIARY AIDS AND SERVICES:

Goodskin Dermatology shall provide, free of charge, the appropriate auxiliary aids or services when necessary to afford individuals with disabilities an equal opportunity to enjoy the program, activities, services, and other benefits:

CODAs Plus Interpreting, providing service for the deaf community 360-947-4100

Linguava Interpreters, language service provider 503-265-8515

2A. FOR PERSONS WHO ARE DEAF OR HARD OF HEARING

To ensure effective communication with individuals who are deaf or hard of hearing, Goodskin Dermatology utilizes qualified interpreter contractors who appear via a dedicated, virtual connection or on-site and interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.

For persons who are deaf/hard of hearing and who use sign language as their primary means of communication, when an interpreter is necessary to provide an equal opportunity to participate in or enjoy our program, activities, services, and other benefits, Goodskin Dermatology will provide one. Goodskin Dermatology utilizes an interpreter service, which provides qualified interpreters who, via a video remote interpreting service (VRI) or an on-site appearance, can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.

The contact information for the interpreter service provider is:

CODAs Plus Interpreting, providing service for the deaf community 360-947-4100

Staff will document the use of the interpreter service used to effectively communicate with the individual in the individual’s record. If the individual returns, staff will not require the individual to repeat the request or recall the auxiliary aid and/or service previously utilized. Instead, staff will confirm with the individual whether the auxiliary aid and/or services previously provided are still needed.

Goodskin Dermatology utilizes relay services for external telephones with text telephone (TTY) users. We accept and make calls through a relay service. The state relay service number is 800-735-2900.

If necessary, staff may contact clinic manager for any additional assistance regarding our resources to effectively communicate with individuals with disabilities over the telephone. Staff will document the use of the method of telephone communication used to effectively communicate with the individual in the individual’s record. If the individual returns, staff will not require the individual to repeat the request or recall the auxiliary aid and/or service previously utilized. Instead, staff will confirm with the individual whether the auxiliary aid and/or services previously provided are still needed.

The following are additional auxiliary aids and services that [name of covered entity] offers and are readily available to ensure that communications with people with disabilities are as effective as communications with others: Text messages using Klara, Portal messages, Emails.

If an individual with a disability requires an auxiliary aid or service not listed above, staff will contact clinic manager to arrange for the provision of the necessary auxiliary aid or service.Any auxiliary aids or 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. Staff will document the use of the appropriate auxiliary aids and services used to effectively communicate with the individual in the individual’s record.

Some persons who are deaf or hard of hearing may prefer or request to use an adult that accompanies them to communicate with Goodskin Dermatology. Goodskin Dermatology may rely upon the adult that accompanies the individuals with a disability to communicate with the individual only after we have effectively communicated to the individual that we are willing to provide them appropriate auxiliary aids and services, including an interpreter, free of charge. Additionally, Goodskin Dermatology will not rely on an adult accompanying an individual with a disability to interpret or facilitate communication except:

(a) In an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available (for example, directly following a natural disaster such as an earthquake); or (b) Where the individual with a disability specifically requests that the accompanying adult interpret or facilitate communication, the accompanying adult agrees to provide such assistance, and reliance on that adult for such assistance is appropriate under the circumstances.

Staff will document that we permitted an accompanying adult to effectively communicate with the individual in the individual’s record. Auxiliary aid and/or service that are provided to an individual when they first contact Goodskin Dermatology should again be made available to that individual if the individual returns to Goodskin Dermatology, unless the individual confirms that they no longer require the auxiliary aid and/or service.

Goodskin Dermatology will not rely on a minor child to interpret or facilitate communication, except in an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available (for example, directly following a serious car accident where, due to the nature of the injuries sustained by an individual with a disability, critical care is a priority). Staff will document the use of a minor child to effectively communicate with the individual in the individual’s record.

If it would be inappropriate to rely on the adult accompanying an individual with a disability for any of these reasons, staff will arrange alternative auxiliary aids and services, including interpreter services, free of charge.

2B. FOR PERSONS WHO ARE BLIND OR WHO HAVE LOW VISION

Goodskin Dermatology staff will assist individuals who are blind or have low vision fill out forms when necessary to afford those individuals an equal opportunity to participate in and benefit from our programs, activities, services, and other benefits.

Goodskin Dermatology staff will provide written documents and materials to an individual who is blind or has low vision in a timely manner in an appropriate alternate format, including converting written documents, such as materials concerning treatment, benefits, services, waivers of rights, and consent to treatment forms, to large print, Braille, audio recordings, and/or to an electronic format, when necessary to afford persons an equal opportunity to participate in and benefit from our programs, activities, services,and other benefits unless it would be a fundamental alteration or undue burden. These alternately formatted documents may be obtained by contacting Goodskin Dermatology.

Staff are available to communicate the information contained in important written documents, including materials concerning treatment, benefits, services, waivers of rights, and consent to treatment forms by reading aloud and explaining these forms to persons who are blind or have low vision when necessary to ensure effective communication.

Staff will document the alternate format used to effectively communicate with the individual in the individual’s record. Auxiliary aid and/or service that are provided to an individual when they first contact Goodskin Dermatology should again be made available to that individual if the individual returns to Goodskin Dermatology, unless the individual confirms that they no longer require the auxiliary aid and/or service.

2C. FOR PERSONS WITH SPEECH DISABILITIES

To ensure an individual with speech impairments or disabilities has an equal opportunity to participate in our program, activities, services, and other benefits, staff will confirm which auxiliary aids and services the individual prefers and then provide appropriate auxiliary aids and services, if available, to the individual in a timely manner.

Staff will document the alternate format used to effectively communicate with the individual in the individual’s record.

Auxiliary aid and/or service that are provided to an individual when they first contact Goodskin Dermatology should again be made available to that individual if the individual returns to Goodskin Dermatology, unless the individual confirms that they no longer require the auxiliary aid and/or service.

2D. FOR PERSONS WITH OTHER TYPES OF DISABILITIES

Goodskin Dermatology staff will provide each individual with a disability with necessary auxiliary aids and services sufficient to afford an equal opportunity to participate in our programs, activities, services, and other benefits. Staff will give primary consideration to the request of the individual with a disability in determining which auxiliary aids and services to provide and will provide the necessary auxiliary aids and services to the individual in a timely manner.

If an individual with a disability requires an auxiliary aid or service that is not readily available, staff shall contact Clinic Manager to arrange for the timely provision of the necessary auxiliary aid or service.

Staff will document the auxiliary aids and services used to effectively communicate with the individual in the individual’s record. Auxiliary aid and/or service that are provided to an individual when they first contact Goodskin Dermatology should again be made available to that individual if the individual returns to Goodskin Dermatology, unless the individual confirms that they no longer require the auxiliary aid and/or service.

3. TRAINING

Goodskin Dermatology will ensure that all relevant staff are trained on the requirements for effective communication as set forth in this document.

LANGUAGE ACCESS PROCEDURES:

In accordance with Section 1557, this document describes Goodskin Dermatology process for providing language assistance services to individuals with limited English proficiency (LEP). This process is designed to help staff take reasonable steps to provide meaningful access for individuals to whom this policy applies, including patients and their companion(s). A companion includes a family member, friend, or associate of an individual seeking access to our services, programs, or activities, who, along with such individual, is an appropriate person with whom we should communicate.

Where language assistance services are required, they must be provided free of charge, be accurate and timely, and protect the privacy and the independent decision-making ability of the individual with LEP. Language assistance services that are provided to an individual with LEP when they first contact Goodskin Dermatology should again be made available to that individual if the individual returns to Goodskin Dermatology, unless the individual confirms that they no longer require language assistance services.

1. IDENTIFYING INDIVIDUALS WITH LEP AND THEIR PRIMARY LANGUAGE(S)

Goodskin Dermatology will promptly identify the language and communication needs of an individual with LEP. If necessary, staff will use a language identification card (or “I speak” cards available online at www.lep.gov) or posters to determine the language of communication.

Staff will document the use of language assistance services in the individual’s record, including any language assistance services necessary to communicate with companions, and such documentation will identify the individual’s or the companion’s preferred language.

2. OBTAINING ORAL LANGUAGE ASSISTANCE SERVICES

Goodskin Dermatology utilizes a telephone interpreter service, which provides qualified interpreters who have demonstrated proficiency in speaking and understanding both spoken English and at least one other spoken language, are able to interpret effectively, accurately, and impartially to and from such language(s) and English, using any necessary specialized vocabulary or terms without changes, omissions, or additions and while preserving the tone, sentiment, and emotional level of the original oral statement. The interpreters must also adhere to generally accepted interpreter ethics principles, including client confidentiality.

The contact information for the interpreter service provider is: Linguava Interpreters (503) 265-8515

To obtain a qualified interpreter from our interpreter service provider:

(i) Contact the language interpreter service identified above; (ii) Communicate with the individual using the language interpreter service; and (iii) Document use of interpreter service provider in the individual’s record.

3. WHEN INDIVIDUALS REQUEST A COMPANION INTERPRETER

Some individuals with LEP may request to use a companion as an interpreter. Companions of an individual with LEP shall not be used as interpreters unless specifically requested by that individual and only after we have communicated in the individual’s primary language that we are willing to provide a qualified interpreter to the individual free of charge.

Unless there is a medical emergency, minor children and other clients/patients/residents will not be used to interpret, to ensure confidentiality of the information and accurate communication.

If the individual declines our language assistance services and wishes to have the companion interpret, confirm the following:

• The companion agrees to provide such assistance;
• Reliance on the companion for such language assistance is appropriate under the circumstances. When determining appropriateness, staff should consider:
  • competency of interpretation;
  • confidentiality/privacy;
  • whether the presence of the companion raises any safety concerns; and
  • whether there is a conflict of interest.
• If relying on the companion for any of these reasons would be inappropriate, staff shall take reasonable steps to provide available alternative interpreter services to the individual with LEP free of charge pursuant to Section 2 of this procedure.
• Document the use of a companion or interpreter service provider in the individual’s record.

4. PROVIDING NOTICE TO INDIVIDUALS WITH LEP

Goodskin Dermatology will inform individuals with LEP about the availability of free-of-charge language assistance services, and all necessary auxiliary aids and services as appropriate for a person with LEP and a disability by providing written notice in languages that persons who are LEP will understand. At a minimum, notices and signs will be clearly and prominently posted and provided on the company website.

5. PROVIDING WRITTEN TRANSLATIONS

Goodskin Dermatology utilizes a translation service, which provides qualified translators who have demonstrated proficiency in writing and understanding both written English and at least one other written non-English language, are able to translate effectively, accurately, and impartially to and from such language(s) and English, using any necessary specialized vocabulary or terms without changes, omissions, or additions and while preserving the tone, sentiment, and emotional level of the original written statement. The translators must also adhere to generally accepted translator ethics principles, including client confidentiality.

Goodskin Dermatology will make vital written materials available for individuals with LEP in the same manner as those made available for English speakers. Vital documents and common forms include: admissions paperwork, applications, required notices (such as Notice of Privacy Practices, Notice of Nondiscrimination, Notice of Availability of Language Assistance Services and Auxiliary Aids and Services, etc.), discharge instructions, billing information, etc.

The contact information for the translation service provider is: Linguava Interpreters (503) 265-8515

• Goodskin Dermatology will submit vital documents or common forms for translation into regularly encountered languages to Linguava Interpreters. We will ensure that the original documents submitted for translation are in final, approved form with updated and accurate legal and medical information.
• Goodskin Dermatology will provide translation of other written materials, if needed, for individuals with LEP free of charge.
• If Goodskin Dermatology does not have a translated document available, staff will submit documents to Linguava Interpreters for translation into the appropriate language.
• Document the use of the translation service provider in the individual’s record.

6. TRAINING OF STAFF

Goodskin Dermatology will ensure that all relevant staff are trained on how to access and provide language assistance services set forth in this document.

GRIEVANCE PROCEDURES:

In accordance with Section 1557 of the Affordable Care Act (Section 1557), it is the policy of Goodskin Dermatology to not discriminate on the basis of race, color, national origin (including limited English proficiency and primary language), age, disability, or sex, including sex characteristics, including intersex traits; pregnancy or related conditions; sexual orientation; gender identity, and sex stereotypes.

This is the grievance procedure for providing prompt and equitable resolution of complaints alleging any action prohibited by Section 1557 and its implementing regulations at 45 C.F.R. Part 92, issued by the U.S. Department of Health and Human Services. Section 1557 and its implementing regulations may be examined at https://www.hhs.gov/civil-rights/for-individuals/section-1557/index.html

Any person who believes that Goodskin Dermatology subjected someone to discrimination prohibited by Section 1557 may file a grievance under this procedure.

Filing a grievance does not prevent a person from pursuing other legal or administrative remedies, including filing a complaint of discrimination on the basis of race, color, national origin, sex, age, or disability in court or with the U.S. Department of Health and Human Services, Office for Civil Rights. A person can file a complaint of discrimination electronically through the Office for Civil Rights Complaint Portal, which is available at: https://ocrportal.hhs.gov/ocr/smartscreen/main.jsf, or by mail or phone at:

U.S. Department of Health and Human Services 200 Independence Avenue, SW Room 509F, HHH Building Washington, D.C. 20201

1-800-368-1019 TDD: 1-800-537-7697 It is against the law for Goodskin Dermatology to intimidate, threaten, coerce, retaliate, or otherwise discriminate against anyone who files a grievance, or participates in the investigation of a grievance for the purpose of interfering with any right or privilege secured by Section 1557.

Procedure:

• Grievances must be submitted to the Section 1557 Coordinator within 60 days of the date the person filing the grievance becomes aware of the alleged discriminatory action.
• A grievance should generally be in writing, containing the name and contact information of the person filing it as well as the alleged discriminatory action and alleged basis (or bases) of discrimination, the date the grievance was filed, and any other pertinent information.
• When a grievance includes allegations that would violate Section 1557, the Section 1557 Coordinator (or their designee) shall investigate the grievance. This investigation may be informal, but it will be thorough, affording all interested persons an opportunity to submit evidence relevant to the grievance.
• Goodskin Dermatology shall inform an individual that they have a right to reasonable modifications in the grievance procedure if they need them.
• The Section 1557 Coordinator must keep confidential the identity of an individual who has filed a grievance under this part except as required by law or to carry out the purposes of this part, including the conduct on any investigation, including to investigate the grievance.
• Goodskin Dermatology will issue to the person who filed the grievance a written decision on the grievance no later than 30 days after its filing. The decision shall include the resolution date and a notice to the complainant of their right to pursue further administrative or legal remedies.
• Goodskin Dermatology will maintain the files and records relating to such grievances for at least three years from the date Goodskin Dermatology resolves the grievance.

The person filing the grievance may appeal the written decision by writing to the Compliance Officer within 15 days of receiving the decision. The Compliance Officer shall issue a written decision in response to the appeal no later than 30 days after its filing.

Goodskin Dermatology through the Section 1557 Coordinator, will make appropriate arrangements to ensure that individuals with disabilities and individuals with limited English proficiency are provided reasonable modifications, appropriate auxiliary aids and services, or language assistance services, respectively, if needed to participate in this grievance process. Such arrangements may include but are not limited to providing these services in a timely manner and without cost to individuals being served to ensure that individuals have an equal opportunity to participate in the grievance process.