Corporate Competency Policy and Plan

This policy applies to all Sunflower Health Plan (Plan) departments (including Provider Relations, Contracting & Network Development, Delegated Vendor Oversight, Medical Management, Marketing, Quality, Customer Service, Training, and Human Resources), participating providers (including hospitals, pharmacies and other ancillary providers), subcontractors, affiliates, and delegates. Each Plan department is required to meet the cultural and linguistic appropriate competency standards that are interwoven in their core business areas.

To provide clarity regarding the provision of cultural, linguistic, and disability access services. The provisions outlined in this policy are in accordance with federal regulatory and Medicaid managed care contract requirements, as well as the National Standards for Culturally and Linguistically Appropriate Services in Health and Health Care (The National CLAS Standards), as developed by the U.S. Department of Health and Human Services Office of Minority Health. The objectives of the Cultural Competency Plan (CCP) include:

• Reduce health care disparities in clinical area;
• Improve cultural competency in materials and communications;
• Improve network adequacy to meet the needs of underserved groups; and
• Improve other areas of needs the organization deems appropriate.

Sunflower Health Plan shall promote and participate in KDHE’s efforts to ensure that covered services are delivered in a culturally competent manner to all members and is responsive to members’ health literacy needs, including those with limited English proficiency (LEP) and diverse cultural and ethnic backgrounds, disabilities, and regardless of gender, sexual orientation or gender identity.

The Plan is committed to developing, strengthening, and sustaining healthy provider/member relationships. Members are entitled to receive dignified, appropriate, and quality care. When healthcare services are delivered without regard for cultural differences, members are at risk for sub-optimal care. Members may be unable or unwilling to communicate their healthcare needs in an insensitive environment, reducing effectiveness of the entire healthcare process. Providers should note that the experience of a member begins at the front door. Failure to use culturally and linguistically competent practices could result in the following:

• Feelings of being insulted or treated rudely
• Feelings of frustration or anger
• Reluctance and fear of making future contact with the office
• Confusion and misunderstanding
• Treatment non-compliance
• Feelings of being uncared for, looked down on, or devalued
• Parents resisting to seek help for their children
• Unfilled prescriptions
• Missed appointments
• Misdiagnosis due to lack of information sharing
• Wasted time
• Increased grievances

• The Plan requires all of our providers and subcontractors to:
  • Follow the Plan’s policies and procedures on providing accessible, culturally and linguistically competent care.
  • Ensure equal availability of services to all members, regardless of communication needs, race, color, national origin, religion, sex, age or disability (including AIDS or other disease state).
  • Provide full and equal access to healthcare services and facilities, make reasonable modifications necessary to make services accessible, and provide effective communication methods to meet the needs of all members, including those with disabilities.
  • Provide flexible scheduling to meet the needs of their members.
  • Provide members, upon request, with information regarding accessibility, and languages, including the ability to communicate with sign language.
  • Provide accessible, culturally and linguistically competent care.
  • Communicate with members in a manner that accommodates their individual needs and interpreters who work with Sunflower to coordinate specialized services (e.g., including medical interpreters for all members, hearing impaired services for those who are deaf or hard of hearing, and accommodations for enrollees with cognitive limitations).
  • Provide oral interpretation services free of charge for all non-English languages.
  • Notify members that oral interpretation is available and how to access those services.
  • Use professional interpreters rather than untrained individuals, family members and/or minors.
• Sunflower’s Cultural, Linguistic and Disability Competency Plan will be available to all network Providers via the Provider Manual and Sunflower website.

• Maintain and update Member Demographic Information
  • The Plan has a membership database, CRM and/or OMNI, to capture member demographic information including race, ethnicity, and preferred language. The CRM and/or OMNI software application is primarily used by Member Services to track customer interactions, and update member demographic and primary care provider information.
• Care Management Population Assessment
  • At least annually, Medical Management assesses the services utilized by the entire member population and any relevant subpopulations (examples may include but are not limited to: Individuals who are Medicare Dual-Eligible, Aged, Blind, Disabled, on Home and Community Based Waivers, Adults and Children with Special Health Care Needs) to determine if the Plan is meeting the cultural, linguistic, and disability access needs of members, or if there are gaps in care with certain populations. The population assessment includes a demographic analysis of member composition by race, ethnicity, preferred language, age group, and sex.
• Members have the right to choose any network provider based on cultural preference. Members may submit grievances to the Plan, or to the State, related to inability to obtain culturally appropriate care.
• Customer Service representatives and Care Managers shall receive Cultural Competency training as part of the new hire training plan and annually thereafter. Training includes computer based online modules, informational videos on Person Centered care, instructions on using and scheduling interpreters, and finding providers to meet cultural, language or disability needs of our members. In addition, Care Managers receive training on health literacy and how to present health information in a manner that is easily understood. When presenting health information to Members, Care Managers are trained to test for understanding and to follow up with additional education or other resources and supports if it appears the Member does not understand the information presented.
• Sunflower’s Cultural, Linguistic, and Disability Competency Plan will be available to all members via the Member Handbook and Sunflower website.
• The Plan addresses member language needs beginning with the Welcome section of the Member Handbook. Member materials are produced in English and Spanish. Other language or format requests are accomplished through translation, interpreters, or appropriate accessible formats.
• Plan contracts with Centene’s language line vendor enabling Plan staff to communicate in the member’s primary language via phone and in person, and is available 24 hours a day, 7 days a week, at no charge to the member.

• The Quality Improvement Committee (QIC) develops and annually updates a CCP that addresses the cultural, linguistic, and disability access needs identified in the population assessment.
  • The QIC works closely with the Member Advisory Committee and LTSS Community Stakeholder Committee to ensure member and community input on plan performance and potential health plan service improvements.
• The Chief Medical Director is responsible for oversight of the CCP, including annual approval of the CCP. The CCP is also annually reviewed and approved by the Quality Improvement Committee (QIC).
• The CCP addresses, at a minimum, the following:
  • Plan’s strategy for recruiting staff with backgrounds representative of Enrollees served;
  • The availability of interpretive services;
  • The availability of transportation services;
  • Plan’s ongoing strategy to meet the unique needs of Enrollees who have developmental disabilities and cognitive disabilities and its operation;
  • Plan’s ongoing strategy to provide services for home-bound Enrollees and the strategy’s operation;
  • Plan’s ongoing strategy to engage local organizations to collaborate on initiatives to increase and measure the effectiveness of culturally competent service delivery and its operation; and
  • Standards and performance requirements for the delivery of culturally and linguistically appropriate health care services.

Through the Sunflower Health Risk Screening tool, Sunflower will identify members who would potentially benefit from referral to a community resource for a social determinant need such as housing, food access, transportation and/or employment. Sunflower’s SDoH team provides subject matter expertise to our Care Managers on each type of social determinant and what the potential community resources are. This team also provides training at least annually to our Care Managers. Sunflower maintains a list of SDoH community resources on our website as a resource to our Members.

Sunflower Health Plan evaluates the cultural competency level of its network providers and provides access to training and resources to assist providers in developing culturally competent and culturally proficient practices. Network providers ensure:

• Members understand that they have access to medical interpreters, signers, and TDD/TTY services to facilitate communication without cost to them
• Medical care is provided with consideration of the member’s race/ethnicity and language and its impact/influence on the member’s health or illness
• Office staff that routinely interact with members have access to and participate in cultural competency training and development
• Office staff responsible for data collection makes reasonable attempts to collect race- and language-specific member information. Staff will also explain race/ethnicity categories to a member so that the member is able to identify the race/ethnicity of themselves and their children
• Treatment plans are developed with consideration of the member’s race, country of origin, native language, social class, religion, mental or physical abilities, heritage, acculturation, age, gender, sexual orientation, and other characteristics that may influence the member’s perspective on healthcare
• Office sites have posted and printed materials in English and Spanish, and other prevalent non-English languages

Cultural Competency Checklist

• Sunflower Health Plan offers a choice of providers with cultural and linguistic expertise.
• Sunflower Health Plan expects the provider to be knowledgeable about their patient’s culture and to use this information in treating their problem.
• Sunflower Health Plan expects the provider to ask questions relevant to how the family and culture values might influence how the patient deals with being sick.
• Sunflower Health Plan offers a program that covers benefits for risk factors common among ethnic groups.
• Sunflower Health Plan empowers the patient by allowing them to influence how the system will meet their needs and expects the patient to be socially responsible and accountable.
• Sunflower Health Plan encourages the provider to listen to the patient’s opinion in considering treatment options.

• Provider Engagement Specialists/Managers, at the point of contact, make Providers aware of interpreter services that are available through Centene Corporation, including American Sign Language, as well as materials in English, Spanish and other languages as needed, and in alternative formats, such as large-print or Braille, based on member needs. Additionally, Provider Relations offers Network providers with training sufficient to ensure accurate and effective communication through quarterly provider trainings or on-site visits upon request. Training includes Americans with Disabilities Act (ADA) requirements.
• Notification of Provider Training opportunities: Sunflower Health Plan will alert providers to upcoming training through email communications and public website. In addition, regional provider specialists will discuss upcoming training events during new provider, routine, and PRN site visits.
• Plan Subcontractors are required to complete cultural, linguistic, and disability competency training at the point of contact and annually thereafter. Competency training is available to all Plan subcontractors on the Plan vendor website. The Delegated Vendor Oversight Committee tracks and monitors subcontractor compliance with required training.
• The Plan supports Network development by recruiting Providers of diverse racial, ethnic, and linguistic backgrounds that reflect the diversity of the membership in order to meet the cultural needs and preferences of Plan enrollees. Provider data is captured during the credentialing and re-credentialing process.
• The U.S Department of Health and Human Services' Office of Minority Health has published online educational programs to Advance Health Equity at Every Point of Contact through development and promotion of culturally and linguistically appropriate services. Plan providers can access Think Cultural Health at www.thinkculturalhealth.hhs.gov to view the free online resources.
• Plan Provider Directory and online Find A Provider will indicate each provider’s linguistic capabilities, as well as whether the Provider has completed cultural competence training, and whether the Provider’s offices, exam rooms, and equipment accommodate individuals with physical disabilities.
• If the Plan identifies a problem involving discrimination or accommodations for individuals with disabilities by a participating provider or Plan subcontractor, the plan shall promptly intervene and require a Corrective Action Plan. The Centene Provider Accessibility Initiative is another option providers can apply for that assists with accommodations for members with disabilities with an overall goal of increasing the percentage of network providers who meet minimum federal and state disability access standards.
• The Plan’s Cultural Competency Plan will be outlined in the provider manual and available on the Plan public website.
• Sunflower will use its GeoAccess data and information gathered from regional provider specialists and other community contacts to identify geographic areas of access deficiency across the state.
• Sunflower will increase access to care as needed through the use of telemedicine per KS.CONT.11.

• All new Plan employees receive cultural, linguistic, and disability competency training as part of their new employee orientation process and are required to complete training annually thereafter. Competency training is distributed through Centene’s online Learning Management System and through the Plan’s Training and Education department. The Training and Education department is responsible for the accurate recording of all training by Plan employees.
• The U.S Department of Health and Human Services' Office of Minority Health has published online educational programs to Advance Health Equity at Every Point of Contact through development and promotion of culturally and linguistically appropriate services. Plan staff can access Think Cultural Health at www.thinkculturalhealth.hhs.gov to view the free online resources.
• The Plan’s Human Resources Department supports workforce development by recruiting, hiring, developing and promoting a culturally, linguistically, and disability-diverse workforce that reflects the diversity of the membership and has a familiarity with the counties served, cultural norms, and how people access health care, within the conditions imposed by Executive Order 11246 (EEO) prohibiting employment discrimination based upon Race, Color, Religion, Sex, Sexual Orientation, Gender Identification or National Origin.

• The Quality Improvement Committee (QIC) assists the Plan to meet the cultural, linguistic, and disability needs of its members by monitoring health plan and provider performance, and implementing interventions to improve the delivery of culturally competent services.
• Member access to cultural, linguistic, and disability services is monitored via:
  • Regular Provider outreach and training;
  • Comparison of the cultural and linguistic diversity of the Plan’s membership to that of the Plan’s Provider Network
  • Member grievances and appeals;
  • CAHPS and/or other member satisfaction surveys;
  • Provider ADA Compliance Attestations;
  • ADA site assessments;
  • Language line and Interpreter usage reports;
  • Provider surveys; and
  • Staff and stakeholder feedback.
• The QIC completes an annual evaluation of the effectiveness of the CCP as part of the annual QI Program Evaluation. Evaluation findings will be used by the QIC in developing an annual CCP for the subsequent year. The Quality Department submits the annual QI Program Evaluation to KDHE annually.

• The Quality Improvement Committee (QIC) assists the Plan to meet the cultural, linguistic, and disability needs of its members by monitoring health plan and provider performance, and implementing interventions to improve the delivery of culturally competent services.
• Member access to cultural, linguistic, and disability services is monitored via:
  • Regular Provider outreach and training;
  • Comparison of the cultural and linguistic diversity of the Plan’s membership to that of the Plan’s Provider Network
  • Member grievances and appeals;
  • CAHPS and/or other member satisfaction surveys;
  • Provider ADA Compliance Attestations;
  • ADA site assessments;
  • Language line and Interpreter usage reports;
  • Provider surveys; and
  • Staff and stakeholder feedback.
• The QIC completes an annual evaluation of the effectiveness of the CCP as part of the annual QI Program Evaluation. Evaluation findings will be used by the QIC in developing an annual CCP for the subsequent year. The Quality Department submits the annual QI Program Evaluation to KDHE annually.

• 42 CFR § 422.503(b)(4)(vi)
• 42 CFR 438.206
• Executive Order 11246 (EEO) Equal Employment Opportunity
• KanCare 2.0 Contract, Section 5.5.4
• LS.MA.011 LifeShare CCP
• EPC.QI.14 EPC CCP
• OC.CC.0006 EPC Vision CCP                                                                                
• OC.ND.0029 EPC Vision Member Cultural Needs and Preferences
• ENVD.QM.09 EPC Dental Assessment Planning and Service Delivery for a
• Culturally Diverse Membership
• 2018 NCQA Standards for Culturally and Linguistically Appropriate Services in Health Care (CLAS Standards)
• HHS CLAS Standards https://www.thinkculturalhealth.hhs.gov/clas
• KS.CONT.11 Telemedicine/telehealth

• Quality Improvement Committee (QIC): The QIC is responsible for the establishment of an ongoing mechanism for ensuring continuous quality improvement as it relates to consumer satisfaction, performance, and outcome data.
• Subcontractor: An organization contracted to provide support or perform a service via a subcontractor Agreement on behalf of Sunflower Health Plan.
• Member Advisory Committee and Long Term Support Services Community Stakeholder Committee: Group of members, or individuals representing those members, community stakeholders, and Sunflower staff that is responsible for providing Sunflower with recommendations from a member- and community-based perspective to improve health plan performance.
• Cultural Competency: Refers to the practices and behaviors that ensure that all members receive high-quality, effective care, irrespective of cultural background, language proficiency, socioeconomic status, and other factors that may be informed by a member’s characteristics.
• Health Literacy: The degree to which individuals have the capacity to obtain; process, and understand back health information and services needed to make appropriate health decisions.