The HEP FAs, as defined in contract, provide a roadmap of required areas a CCO needs to address to comply with state, federal and contractual requirements and reduce health inequities and disparities, provide healthcare access and improve member health outcomes.
The HEP is not meant to function in isolation from the CCO's work in other areas of the organization. CCOs are not expected to develop a separate set of projects to fulfill the requirements of the Health Equity Plan. OHA expects the plan to complement other organization-wide efforts such as CCO strategic planning, Community Health Assessment/Community Health Improvement Plan, CCO work on Social Determinants of Health, Healthier Oregon Program, and 1115 Medicaid Waiver implementation and other initiatives. The HEP will provide evidence to OHA that health equity is integrated into all functions of the CCO as an organization.
Note: FAs below include references to the contract. The references are not comprehensive and only point to sections or exhibits in the contract where the CCO can find some FA elements required and only aim to illustrate the HEP should be embedded in the CCO structure and operations.
a) REALD & SOGI[1].
Under this focus area, Contractor is able to document organizational efforts on organizational methods and processes for:
- The utilization of REALD and SOGI data to advance Health Equity.
- Assessing gaps in the current demographic data systems and processes (both Contractor's and Contractor's Provider Network).
- Identifying the challenges encountered in collecting demographic data (both Contractor's and Contractor's Provider Network); and
- Developing actionable plans for the collection, analysis, and reporting of demographic data to meet both federal and state reporting requirements and facilitate the analysis of the demographic data within the Communities of Contractor's Service Area in order to identify and address SDOHE disparities.
(Exhibit K – Social Determinants of Health and Equity; Exhibit B – Statement of Work – Part 2 – Covered and Non-Covered Services; Exhibit B – Statement of Work – Part 3 – Patient Rights and Responsibilities, Engagement and Choice; Exhibit B – Statement of Work – Part 4 – Providers and Delivery System)[2]
OHA Expectations:
- The CCO utilizes demographic data collection and analysis to advance health equity as a strategic priority as evidenced by:
- The CCO has the capability to identify gaps and challenges in its current data collection, analysis systems and process, and develops organization-wide actionable goals to address them.
- The CCO provides evidence and examples of how it uses REALD and SOGI data to eliminate health inequities by identifying population-specific health inequities and developing targeted programs and interventions informed by REALD / SOGI data.
Resources:
- Using REALD and SOGI to Identify and Address Health Inequities https://www.oregon.gov/oha/EI/Pages/Demographics.aspx
b) Using CLAS Standards[3] as an organizational framework to advance health equity.
Under this focus area, Contractor is able to document its efforts developing organizational systems and processes to provide effective, equitable, understandable, and respectful quality health care and services by focusing on CLAS Standards related, but not limited, to “Governance, Leadership, and Workforce" and “Communication and Language Assistance" which in large have been areas where CCOs have focused efforts on the implementation of CLAS.
OHA Expectations:
- The CCO has at least one strategy and related goal for each of the National CLAS standards categories:
- Workforce, Governance, and Leadership: Strategies/goals related to organizational governance, training, and policy incorporating CLAS standards and workforce diversity recruitment and retention.
- Advance and sustain organizational governance and leadership that promotes CLAS and health equity through policy, practices, and allocated resources.
- Recruit, promote, and support a culturally and linguistically diverse governance, leadership, and workforce that are responsive to the population in the service area.
- Educate and train governance, leadership, and workforce in culturally and linguistically appropriate policies and practices on an ongoing basis.
(CCO Contract Exhibit B Part 4 Providers and Delivery Systems (4); Exhibit K Part 10; Exhibit K Part 11 Traditional Health Workers):
- Communication and Language Assistance: Strategies/goals related to CLAS-compliant language assistance and member accessibility of materials.
- Offer language assistance to individuals who have limited English proficiency and/or other communication needs, at no cost to them, to facilitate timely access to all health care and services.
- Inform all individuals of the availability of language assistance services clearly and in their preferred language, verbally and in writing.
- Ensure the competence of individuals providing language assistance, recognizing that the use of untrained individuals and/or minors as interpreters should be avoided.
- Provide easy-to-understand print and multimedia materials and signage in the CCO service area most prevalent languages.
(CCO Contract Exhibit B Part 3 Patients' Rights and Responsibilities-Engagement and Choice; Exhibit B Part 4 Provider and Delivery System; Exhibit K Part 10 Health Equity Plan; Exhibit M-Behavioral Health):
- Engagement, Continuous Improvement, and Accountability:
- Establish culturally and linguistically appropriate goals, policies, and management accountability, and infuse them throughout the organization's planning and operations.
- Conduct ongoing assessments of the organization's CLAS-related activities and integrate CLAS-related measures into measurement and continuous quality improvement activities.
- Collect and maintain accurate and reliable demographic data to monitor and evaluate the impact of CLAS on health equity and outcomes and to inform service delivery.
- Conduct regular assessments of community health assets and needs and use the results to plan and implement services that respond to the cultural and linguistic diversity of populations in the service area.
- Partner with the community to design, implement, and evaluate policies, practices, and services to ensure cultural and linguistic appropriateness.
- Create conflict and grievance resolution processes that are culturally and linguistically appropriate to identify, prevent, and resolve conflicts or complaints.
- Communicate the organization's progress in implementing and sustaining CLAS to all stakeholders, constituents, and the general public.
(CCO Contract Exhibit B Part 4 Providers and Delivery Systems (4); Exhibit K Part 10)
- The CCO has a review mechanism in place to track compliance and progress with CLAS standards, including collecting feedback from community members, CACs, and/or community-based organization partners.
- The CCO shares their annual progress on these goals with the broader community through a public facing report or presentation.
Resources:
c) People with Disabilities and People who identify as LGBTQIA2S+[4]
Under this focus area, Contractor is able to document work on the following three (3) priority populations:
i) People with disabilities and health services.
Under this focus area, Contractor is able to document efforts developing organizational systems and processes to provide effective, equitable, understandable, and respectful quality care and services to individuals with disabilities by ensuring compliance with the Rehabilitation Act, Affordable Care Act, Americans with Disabilities Act, and the Web Content Accessibility Guideline (WCAG) requirements.
(Exhibit B – Statement of Work – Part 9 – Program Integrity ; Exhibit B – Statement of Work – Part 2 – Covered and Non-Covered Services; Exhibit B – Statement of Work – Part 3 – Patient Rights and Responsibilities, Engagement and Choice; Exhibit B – Statement of Work – Part 4 – Providers and Delivery System; Exhibit D – Standard Terms and Conditions; Exhibit E – Required Federal Terms and Conditions; Exhibit I – Grievance and Appeal System; Exhibit K – Social Determinants of Health and Equity; Exhibit M – Behavioral Health)
OHA Expectations:
- The CCO provides an analysis of barriers to accessing care for people with disabilities and uses relevant research to inform continuous quality improvement efforts.
- CCO uses multiple quantitative and qualitative data sources to gain insight into health care utilization and needs of people with disabilities.
- CCO collects disability information consistently with REALD guidelines.
- CCO uses quantitative and qualitative data to shed light on the challenges individuals with disabilities in the CCO community and service area may face.
- CCO has policies and processes in place to ensure materials are developed in plain language and provided to members in alternate formats including different language, braille, large print and audio materials in accordance with contractual, state and federal guidelines.
Resources:
ii) People who identify as transgender, nonbinary, or gender diverse and health services[5]. Under this focus area, Contractor is able to document its efforts developing organizational systems and processes to provide effective, equitable, understandable, and respectful quality care and services to individuals who identify as transgender, nonbinary, or gender diverse by ensuring compliance with the Oregon Equality Act of 2008, the Affordable Care Act, and Title VII of the Civil Rights Act.
(Exhibit B – Statement of Work – Part 3 – Patient Rights and Responsibilities, Engagement and Choice; Exhibit B – Statement of Work – Part 9 – Program Integrity; Exhibit E – Required Federal Terms and Conditions; Exhibit I – Grievance and Appeal System; Exhibit K – Social Determinants of Health and Equity; Exhibit M – Behavioral Health)
OHA Expectations
- The CCO provides an analysis of barriers to accessing care for people who are transgender, nonbinary, or gender diverse and uses relevant research to inform continuous quality improvement efforts.
- CCO uses multiple quantitative and qualitative data to shed light on the barriers and challenges transgender, nonbinary, or gender diverse people in the CCO community and service area may face.
- CCO has established channels and actively engages people who are transgender, nonbinary, or gender diverse to provide feedback and oversight directly to CCO quality assurance.
- CCO has policies and processes in place to assess and ensure that provider network is using state- and nationwide best practices for providing healthcare services for people who are transgender, nonbinary, or gender diverse.
- CCO training plan includes staff education to understand and support transgender, nonbinary, and gender diverse individuals.
Resources:
iii) People with diverse sexual orientations and health services. Under this focus area, Contractor is able to document its efforts developing organizational systems and processes to provide effective, equitable, understandable, and respectful quality care and services to individuals who do not identify as straight or heterosexual by ensuring compliance with the Oregon Equality Act of 2008, the Affordable Care Act, and Title VII of the Civil Rights Act.
(Exhibit B – Statement of Work – Part 3 – Patient Rights and Responsibilities, Engagement and Choice; Exhibit B – Statement of Work – Part 9 – Program Integrity; Exhibit E – Required Federal Terms and Conditions; Exhibit I – Grievance and Appeal System; Exhibit K – Social Determinants of Health and Equity; Exhibit M – Behavioral Health)
OHA Expectations
- The CCO provides an analysis of barriers to accessing care for people who have diverse sexual orientations and uses relevant research to inform continuous quality improvement efforts.
- CCO collects sexual orientation information consistently with SOGI guidelines.
- CCO uses multiple quantitative and qualitative data sources to shed light on the health care utilization, needs, barriers, and challenges people with diverse sexual orientations in the CCO community and service area may face.
- CCO has established channels and actively engages people with diverse sexual orientations to provide feedback and oversight directly to CCO quality assurance.
- CCO has policies and processes in place to assess and ensure that provider network is using state- and nationwide best practices for providing healthcare services for people with diverse sexual orientations.
- CCO training plan includes staff education to understand and support people with diverse sexual orientations.
Resources:
d) CCO community engagement activities[6].
Under this focus area, Contractor is able to document its efforts developing systems and processes to increase organizational capacity to advance health equity by engaging CCO Members and communities in the CCO Service Area for:
- Development of systems and processes to involve community in the development of the Health Equity Plan and Health Equity Plan updates.
- Development of systems and processes that use transformational community engagement[7] methods to engage communities in CCO and CCO partner activities related to advancing health equity in the CCO Service Area; and
- Outreach[8] and engagement of Members using culturally and linguistically appropriate methods that may be identified by the above efforts or by the collaboration with culture specific community-based organizations for the purpose of raising the awareness of the CCO and Subcontractors and CCO partners, available programs and services such as Healthier Oregon Program.
(Exhibit B – Statement of Work – Part 3 – Patient Rights and Responsibilities, Engagement and Choice; Exhibit K – Social Determinants of Health and Equity; Exhibit M – Behavioral Health)
OHA Expectations
- CCO includes member and community voice in the development of the Health Equity Plan yearly updates through CAC or other advisory councils and community partners.
- CCO demonstrates regular, consistent, authentic and transformational engagement of communities, including participation in review and feedback on any appropriate or applicable CCO policy and/or process, Health Equity Plan, and community engagement strategies
- CCO integrates culturally and linguistically appropriate methods into their outreach strategies to members and community-based CBOs, based on feedback and guidance from existing partners / CACs.
- CCO uses a partnership and relationship-building approach to community engagement, developing systems and processes that allow for consistent, long-term, and mutually beneficial (non-extractive) relationships with members and CBOs[9].
- CCO utilizes available resources such as OHA Community Partner Outreach Partner Program, Regional Health Equity Coalitions (when available in the CCO service area) and other culture specific community-based organizations to support the development and implementation of strategies and goals that support transformational community engagement for the purpose of raising awareness of available programs and services.
Resources:
e) Continued development of an organizational Health Equity infrastructure.
Under this focus area, Contractor is able to document the continuation of its efforts developing systems and processes to ensure its organizational capacity to advance health equity, such as organizational commitment and allocation of resources to advance health equity and how CCO is developing organizational structures to support true community collaborations and partnerships.
OHA Expectations
- CCO provides updates on strategies / goals related to organization-wide health equity infrastructure, such as:
- Institutional commitment to advance health equity
- Allocation of resources, training, and FTE positions dedicated to advancing health equity
- Integration of health equity practices and values throughout the organization
- Organizational structures to support true community collaborations
- Findings and actions taken from any organizational equity audits or organizational culture/employee satisfaction surveys
Resources:
[1] “Race, ethnicity, preferred spoken and written languages and disability status standards" and “REALD" each means the standards under ORS 413.161. As of July 1, 2022, pursuant to Enrolled Oregon House Bill 3159 (2021) Section 5, sexual orientation and gender identity are added to the standards under ORS 413.161.
[2] 2023 CCO Contract references are in blue and italicized.
[3] “Culturally and Linguistically Appropriate Services" and “CLAS" each means the provision of effective, equitable, understandable, and respectful quality care and services that are responsive to diverse cultural health beliefs and practices, preferred languages, health literacy, and other communication needs. “Culturally and Linguistically Appropriate Services" includes meaningful language access as required by Title VI Guidance issued by the United States Department of Justice and the National Standards for Culturally and Linguistically Appropriate Services in Health and Health Care as issued by the United States Department of Health and Human Services.
[4] “LGBTQIA2S+" is an acronym for Lesbian, Gay, Bisexual, Transgender, Queer and/or Questioning, Intersex, Asexual, Two-Spirit, and the countless affirmative ways in which people choose to self-identify on the gender expansive and sexual identity spectrums
[5] People with diverse sexual orientations refers to people who identify as lesbian, gay, bisexual, two-spirited, queer, questioning, asexual, or any other sexual orientation identity on the expansive identity spectrum
[6] “Community" has the meaning provided for in ORS 414.018(5)(a).
[7] Transformational Community Engagement to Advance Health Equity https://www.shvs.org/wp-content/uploads/2023/03/SHVS_Transformational-Community-Engagement-to-Advance-Health-Equity.pdf
[8] “Outreach" has the meaning provided for in OAR 410-141-3575.
[9] Transformational Community Engagement to Advance Health Equity https://www.shvs.org/wp-content/uploads/2023/03/SHVS_Transformational-Community-Engagement-to-Advance-Health-Equity.pdf