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I. Policy:

It is the policy of High Fidelity Wrap Erie County (HFW) that all HFW Erie Care Coordination Agencies (CCA) and Vendor Agency management and designated personnel will provide culturally competent services to families throughout the Erie County System of Care (SOC) ensuring families receive effective, understandable, and respectful care that is provided in a manner compatible with their cultural health beliefs, practices, and preferred language. Please Note: Translation Services are a part the gross cost budget submitted by Care Coordination Agencies. Vendor dollars cannot be used for translation services.

The integration of cultural, spiritual, health and healing practices and beliefs which promote the family’s wellness and wellbeing will be integrated in the assessment, planning, intervention and ongoing review of care. Cultural considerations for appropriate care include, but are not limited to ethnicity, race, gender, primary language, English proficiency, sexual orientation, immigration status, acculturation factors, spiritual beliefs and practices, physical abilities and limitations, family roles, community networks, literacy, employment, and economic factors.

Moreover, the implementation of cultural and linguistic competence policies and procedures throughout the system of care is intended to reduce disparities that exist in the system of care related to access and utilization of services, and out of home care.

It is the policy of HFW Erie that all CCA and Vendor Agency management and designated personnel will implement strategies to recruit, retain and promote a diverse staff and leadership that are representative of the demographic characteristics of Erie County.

It is the policy of HFW Erie that all CCA and Vendor Agency management and designated personnel ensure that staff at all levels and across all disciplines receive ongoing education and training in cultural and linguistic competent service delivery.


Cultural Competence is the capacity to value diversity, conduct ongoing self assessment, manage the dynamics of difference, acquire and institutionalize cultural knowledge and adapt to diversity and cultural contexts of the communities.

Culturally Competent services throughout the system of care relates to the individual skills and proficiency of personnel. The organizational practices and promotion of culturally competent must include but are not limited to:

a.  clinical assessments

b.  interventions

c.  practices

d.  training

e.  service approaches

f.  marketing strategies and techniques that support the service population and increase the

    quality and appropriateness of services.

Cultural Competence is a set of values and principles which are reflected throughout the entire SOC.

This includes but not limited to:

  1. behaviors

  1. attitudes

  1. physical agency space

  1. location

Linguistic Competence is the capacity of SOC to communicate effectively, and convey information in a manner that is easily understood by diverse audiences. Linguistic competence involves the development of inter-agency and internal capacity to respond effectively to the permanency, well being and wellness, and developmental literacy of all families in the SOC. In addition, linguistic competence involves meeting the communication needs of the populations served and ensures the policy, structures, practices and procedures support the capacity of the SOC and are continually practiced.

II.   Procedure:

  1. Cultural & Linguistic Competencey (CLC) Plan:

  1. It is the policy of HFW Erie that all CCA and Vendor Agency management and designated personnel create and implement a Cultural and Linguistic Competence policy and plan. CLC Plan should be based on an agency-wide CLC assessment and consider the following domains: Use of community demographic information, needs identification of the community, culturally competent treatment planning, historical information, community-based services and supports, staff development and quality improvement.

2.  Monitoring and Reporting of Quality Assurance CLC Outcomes:

  1. Data and Reporting System:

It is the policy of the HFW Erie that all CCA and Vendor Agency management and designated personnel achieve cultural and linguistic outcomes. Specific outcome areas and related performance metrics are outlined in the SOC contracts and monitored by CCNY, Inc. Pie Performance reports and critical care dashboard(s). These may include but are not limited to “successfully met” discharge rates by race and out of home placement rates by race.

3.  Linguistic Competence & Language Access Services:

   (Please refer to specific Language Access Services Policy in Administrative Section in Policies

   and Procedures under Cultural & Linguistic Competence)

  1. It is the policy of HFW Erie that all CCA and Vendor Agency management and designated personnel to provide readily accessible resources for  families with limited English proficiency (LEP) as well as speech, hearing and visual impairment. This includes but is not limited to bi-lingual or multi-lingual staff, interpreters, special devices and other communication aids as needed to facilitate effective, culturally and linguistically competent communication. The purpose of this policy is to encourage engagement and retention of families in HFW Erie. Interpretation and translation must only be provided by individuals that do not pose a conflict of interest to the family.

     b. HFW Erie, its agents and assignees shall not deny care and treatment to or otherwise

          discriminate on the basis of race, color, national origin, sex, age, disability or against

          persons who are non-English speaking, deaf, or hard of hearing and visually impaired. In

          addition, CCA and Vendor Agency management and designated personnel shall facilitate

          access to services by persons aforementioned.

III.   REFERENCES: FEDERAL LAW: Title VI of the Civil Rights Act of 1964, Section 601, (42 USC 2000d)

Office of Minority Health, U.S. Department of Health & Human Services (2000). Americans with Disabilities Act (Public Law 101-336.)

National Standards for Culturally and Linguistically Appropriate Services (CLAS)

Health Care, Federal Register, 65(247)80865-80879.

New York State Law: Mental Hygiene Regulation 527.4 NYS Public Health Law: 763.1, 766.1 v

Executive Order 13166, New York State Office of Mental Health, Bureau of Cultural Competence Agency Plan Format


Cross, Bazron, Dennis & Issac’s (1989) Towards a Culturally Competent System of Care: A Monograph of Effective Services for Minority Children who are Severely Emotionally Disturbed: Volume I.

Goode and Jones (modified 2004), National Center for Cultural Competence, Georgetown University Center for Children.

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