1.   Footprints to Success will provide Auxiliary Aids/Interpreter Services for clients and their companions who are deaf/hard-of-hearing and/or communicate in a language other than English at no-cost to the client.

2.   Children shall not serve as the primary interpreter for parents or other family members as clients/customers or as companions.

 3.   Footprints to Success will not deny services to any client or companion who is deaf/hard-of hearing.

4.   The Executive Director shall serve as the Single Point of Contact (SPOC) and the ADA Coordinator for Auxiliary Aid Service for the Deaf/hard-of-Hearing. The Chief Operating Officer serves as the back-up SPOC.

5.  All employees of Footprints to Success are required to complete training in the Auxiliary Aid Plan compliance and shall execute a document which indicates their compliance with and the provision of Auxiliary Aid/Free Interpreter Service to Clients/Companions who are Deaf/Hard-Of-Hearing within the first 60 days of the 90-day provisional period of employment and annually thereafter.

6.   Footprints to Success shall retain a signed Attestation of the employees understanding of the ADA Compliance Laws and SPOC in their personnel record.

7.   Footprints to Success shall monitor employee compliance with the training requirement via the employee’s yearly HHS training provided by the Department of Children and Families.

8.   Footprints to Success shall post, in the common area of each facility location, in a prominent place, accessible to everyone, the Florida Department of Children & Families posting of the following:

a. Interpreter Services for the Hearing Impaired

b. DCF Non-discrimination Policy

c. Services to Clients with Limited English Proficiency

 9.  All interpreter service vendors are required to submit evidence of certification/credentials of the qualified interpreters. Verification will be retained by the SPOC.

 10.   All agency groups, meetings, and conferences shall assure accessibility to clients/companions who have disabilities or require an auxiliary aid.

11.   All postings, brochures, and advertising of services shall document the accessibility including the use of 711 Relay.

 12.   Although the agency has TTY capability, all staff use 711 Relay for telephone contact with clients who are deaf/hard-of-hearing.

 13.   Upon approval by the Management Team, the Auxiliary Aid Plan shall be posted on the Agency website as required by DCF/HHS.

14. Upon request, the plan is made available in alternative forms and languages.

15. All clients and companions who are Deaf/Hard-of-Hearing shall be provided with an auxiliary aid at no cost and information on how to file and complete an Agency Grievance if needed.

AUXILIARY AID PROCEDURES

1.   At Screening/Enrollment/Admission, staff with first client contact will document in the record if the client or client companion is:

a.       Deaf/hard-of-hearing

b.       Communicates in a language other than English

c.       Utilizes 711 Relay

2.   Staff shall notify client/client companion/client referral source of the availability of no-cost interpreter services for primary languages and auxiliary aids for the deaf/hard-of-hearing.

3.  Staff shall document the client/companion’s preferred auxiliary aid service in the Call Intake/Enrollment or Progress Note bundle.

4.   If the client/companion is deaf/hard-of-hearing and/or communicate in a language other than English, staff with first client contact by phone will:

a.   Document in the client record a client alert message and:

                                                               i.      Schedule HIS Deaf and Hearing Interpreting Service, Inc Sign-Language Interpreter, or;

                                                             ii.      Schedule/Use a LanguageLine® accessible phone, or;

                                                           iii.      Contact the approved Footprints to Success Interpreter vendor directly.

b.    HIS Deaf and Hearing Interpreting Service, Inc. In-person interpreters shall be the first option for deaf/hard-of-hearing persons.

c.   Language Line® services shall be the first option for languages other than English.

d.    Executive Director is available by agency cell phone if there are questions regarding the Assistive Listening device.

e.     For urgent, same-day, in-person services, contact the vendor by telephone and follow-up with the electronic request.

f.       For non-urgent, future/scheduled appointments the vendor can be scheduled electronically using the approved vendor request form.

g.       Schedule the appointment upon confirmation from the vendor that the interpreter is available.

h.       Copy the agency SPOC on:

                                                               i.      All Interpreter Service Vendor Requests and confirmations

                                                             ii.      All signed DCF Customer/Companion Waiver for Free Interpreter Service Forms.

i.         In order to meet the contractual obligation with the vendor to provide 48 hours’ notice of cancellations, confirm the appointment with the client 48 hours before the scheduled time.

                                                               i.      Language Line® services do not require advance scheduling and cancellation.

j.         Schedule the date and time of the service as a two-hour time block to allow extra time for interpreting.

k.       Do not place clients requiring a live interpreter in the Open Access Intake Schedule.

l.         Staff shall:

                                i.   Confirm all appointments 2 days prior to the service.

                                ii.  Ensure that all scheduled interpreters are canceled with 48 hours’ notice when a client appointment is canceled with notice.

5.    During the first face-to-face contact, program staff shall:

a.       Complete the full DCF Customer/Companion Communication Assessment & Auxiliary Aid/Service Record form/screens in the client record.

b.       Complete and obtain client or companion signature on the DCF Customer/Companion Waiver for Free Interpreter Service or Auxiliary Aid.

c.       Schedule the date and time of future service as a two-hour time block to allow extra time for interpreting.

d.       Contact the approved Footprints to Success interpreter vendor directly.

                                                               i.      Language Line® services will be the first option for languages other than English.

                                                             ii.      HIS Deaf and Hearing Interpreting Service, Inc In-person interpreters will be the first option for deaf/hard-of-hearing.

e.        Assistive Listening Devices shall be available at the front desk for immediate access if a need is assessed. Devices may be reserved with notice or signed out for immediate need.

f.        The Executive Director is available by agency cell phone if there are questions regarding the Assistive Listening device.

g.       For urgent, same-day, in-person services, assigned staff shall contact the vendor by telephone and follow-up with the electronic request.

h.       For non-urgent, future/scheduled appointments the vendor can be scheduled electronically using the approved vendor request form.

i.         Schedule the appointment upon confirmation from the vendor that the interpreter is available.

j.         Copy the agency SPOC on:

                                                               i.      All Interpreter Service Vendor Requests and confirmations.

                                                             ii.      All signed DCF Customer/Companion Waiver for Free Interpreter Service Forms.

k.       In order to meet the contractual obligation with the vendor to provide 48 hours’ notice of cancellations, confirm the appointment with the client 48 hours before the scheduled time.

                                                               i.      Language Line® services do not require advance scheduling and cancellation.

l.         When appointments are scheduled, the COO or directors are authorized to contact the interpreter services approved and sub-contracted by Footprints to Success.

6.       Walk-Ins:

a.       All efforts shall be made to provide interpreter services or Auxiliary Aid for clients

who are Deaf/Hard-Of Hearing within 4 hours of walking into the Agency.

b.       Language Line® Interpreter Services will be used for clients who communicate in a

language other than English.

c.       Footprints to Success staff are required to contact the agency SPOC or the back-up in the event the staff is unfamiliar with the requested auxiliary aid or service or in the event a client presents for services and an auxiliary aid is not timely.

d.       No client is to be turned away due to lack of an auxiliary aid. The SPOC is required to make all efforts to obtain the appropriate auxiliary aid by contacting the DCF Single-Point of Contact documented in the completed training Attestation.

e.       Staff are to contact the SPOC immediately in the event that the auxiliary aid is not effective or in the event the auxiliary aid is denied.

7.       Clients/client companions shall be provided with a Customer Feedback form on the auxiliary/interpreter services after use of the auxiliary aid service to determine effectiveness and satisfaction with the service.

a.       Assistance in completing the form will be provided as requested by the client/client

companion.

b.    All completed forms are to be forwarded to the agency SPOC directly or via email to be retained in the file.

c.    All customer feedback forms are retained by the client for mailing.

8.       Requests for change of auxiliary services/interpreter service shall be accepted and provided

as needed.

9.       A copy of the completed Auxiliary Aid Assessment/Service Record must be maintained by

the Agency SPOC via the electronic medical record of the client.

10.   Clients who would like to file a grievance may contact the Footprints to Success Compliance Officer at 954-657-8010 or the resources listed below:

Department of Children and Families (DCF): Office of Civil Rights

1317 Winewood Boulevard, Building 1, Room 110

Tallahassee, FL 32399-0700

(850) 487-1901; or TDD (850) 922-9220; or Fax (850) 921-8470

United States Department of Health and Human Services (HHS)

Attention: Office for Civil Rights

Atlanta Federal Center, Suite 3B70

AUXILIARY AID PLAN AND PROCEDURES

Plan and Procedures

61 Forsyth Street, SW

Atlanta, Georgia 30303-8909

(404) 562-7888; TDD/TTY (404) 331-2867; or Fax (404) 562-7881