(Approved 9/23/09)(Updated 03/2015)

Policy: In compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the 34 CFR 364.56, and the HITECH law (electronic transmission of health information), the Memphis Center for Independent Living makes use of information and records concerning individuals ONLY for purposes directly connected with the service, including project evaluation activities.

Procedure: Private health information MAY NOT BE DISCLOSED, directly or indirectly, other than in the administration of the service unless the consent of the agency providing the information and the individual to whom the information applies, or their designee, has been OBTAINED IN WRITING.

All information concerning consumers, staff, the Board of Directors, program services, and administration of MCIL is confidential and will be kept confidential and will not be disseminated to anyone outside or inside of MCIL without approval by the Executive Director. Information may include budgetary, salaries, call lists, program rosters, sign in sheets, etc. containing information such as names, phone numbers and service notes. This material shall only be used by staff or assigned volunteers who have been trained and have signed a Confidentiality Statement which is on file and updated annually. Temporary documents must be shredded upon completion of approved use. Permanent records of employee documents will be kept under double lock and key and will only be used by program personnel within the scope of their assigned duties. Consumer services and Consumer Service Records will be handled in compliance with federal guidelines for Centers for Independent Living. Failure to comply with these procedures constitutes grounds for immediate dismissal.

No consumer is required to make public statements of gratitude towards MCIL. No consumer is required to perform at public events. The consumer or designee signature on Sign-in Sheets at MCIL events will constitute written permission to use any photos, video or audio recordings in the promotion of MCIL. This policy will be posted prominently and published in the MCIL newsletter and website.

It is the policy of the Memphis Center for Independent Living not to discriminate against any applicant for employment, or any employee because of age, color, sex, disability, national origin, race, religion, or veteran status.

MCIL will take affirmative action to ensure that the EEO Policy is implemented, with particular regard to: advertising, application procedures, compensation, demotion, employment, fringe benefits, job assignment, job classification, layoff, leave, promotion, recruitment, rehire, social activities, training, termination, transfer, upgrade, and working conditions.

MCIL will continue to make it understood by the employment entities with which it deals, and in employment opportunity announcements that the foregoing is company policy and all employment decisions are based on individual merit only.

All current employees of MCIL are requested to encourage qualified disabled persons, minorities, special disabled veterans, and Vietnam Era veterans to apply for employment, on the job training or for union accommodations for qualified disabled individuals.

It is the policy of MCIL that all company activities, facilities, and job sites are non-segregated. Separate or single-user toilet and changing facilities are provided to assure privacy.It is the policy of MCIL to ensure and maintain a working environment free of coercion, harassment, and intimidation at all job sites, and in all facilities at which employees are assigned to work. Any violation of the policy should be immediately reported to your supervisor or the company EEO Officer.

Consumer Complaint and Grievance Reporting Policy: Independent Living Services maintains documents and procedures for the Consumer complaint process. The process will track and report on the date, time, nature of the complaint; people involved, actions taken and resolution of the complaint.