Our agency

Notice of Privacy Practices

As required by HIPAA, MN Data Practices Act and Tennessen Warning regulations, this notice describes how protected health information about Washburn Center clients may be used and disclosed, and client rights to access and amend their information.

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

The terms of this notice apply to protected health information created or received by Washburn Center. Washburn Center providers will gather health information about you and/or your family. We use the information to establish a diagnosis, determine your treatment plan and goals, process payment, and provide the services you request. You are not required to provide us with health information; however, we may not be able to provide services without it. We are required to keep records of the care that we provide to you.

Except as described in this Notice, Washburn Center will not use or share your health information without specific written permission from you. If you provide us with written permission to use or share health information about you, you may take back that permission, in writing, at any time. If you take back your permission, we will no longer use or share health information about you, except to the extent we have already used or shared information based on the permission you previously gave. We are unable to take back anything we already shared with your permission.

If you feel your rights have been violated, see page 4 for details on how to file a complaint.

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.
• We will promptly tell you if the privacy or security of your information has been compromised, such as a data breach.
• We must follow the duties and privacy practices described in this notice.

Your Rights (for more details, see page 2)

• Review and receive a copy of health records (with some exceptions)
• Request changes to health records (we may or may not approve such requests)
• Request a list of when Washburn Center has shared certain health information about you/your child
• Request limitations on how we use/share health information (we may or may not approve such requests)
• Request confidential communication of health information
• Receive a paper copy of this notice
• Minors can request health information not be shared with parents (we may/may not approve requests)

How we may use or share your information (for more details, see page 3)

• Treatment, payment, and health care operations
• Appointment reminders
• Fundraising
• Sharing health information with people helping you with your healthcare
  Research
• As required by law
• In situations where you or others are in danger or are being harmed (mandated reporting, duty to warn)
• To our business partners that help us perform job duties

Special situations where we may use your information (for more details, see page 4)

Organ and tissue donation, workers compensation, public health, health oversight, lawsuits and disputes, law enforcement, coroner/medical examiner/funeral director, special government functions (secret service, military)

The contents of this site are for informational purposes only. The content is not intended to be a substitute for professional medical advice, diagnosis or treatment.

Always seek the advice of your physician or other qualified healthcare provider with any questions you may have regarding your medical condition.

If you have a medical emergency, call your doctor or 911 immediately.

Returns/Refund Policy

Training Institute Refund Policy
Washburn Center will give a full refund for any cancellations received seven or more days in advance of the first training session.

Cancellations received less than seven days of the training or after will not be refunded.

Donations
Charitable contributions to Washburn Center for Children are considered to be non-refundable gifts.

Privacy Policy

Questions about Washburn Center for Children’s Privacy Policy
This website is owned and operated by Washburn Center for Children (Washburn Center). We recognize that visitors to our site may be concerned about the information they provide to us, and how we treat that information. This privacy policy addresses those concerns. If you have any questions about our privacy policy, please contact:

Washburn Center for Children
1100 Glenwood Avenue
Minneapolis, MN 55405
612.871.1454

Website Information Accuracy
It is the policy of Washburn Center to present correct and accurate information. If inaccuracies come to our attention, Washburn Center will attempt to correct them in a timely manner. To report any website inaccuracies, please email jack.sullivan@washburn.org

Privacy Policy
Washburn Center seeks to respect and protect the privacy of our visitors and only gathers personally identifiable data, such as names, addresses, zip/postal codes, e-mail addresses, etc., when voluntarily submitted by a visitor. We will not sell or rent this information to anyone.

We will use your information to respond to you regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g. to process a donation.

Unless you ask us not to, we may contact you via email in the future to tell you about Washburn Center news, or changes to this privacy policy.

Opt-Out
Visitors may opt out of having their personal information used by Washburn Center to send informational correspondences, by contacting Washburn Center via U.S. mail, by phone, or by checking the appropriate box on either the online donation form or enews.

Disclosure
At times, Washburn Center may be required by law or legal process to disclose information about you to others. Washburn Center may also disclose information about you if it believes that disclosure is necessary for the public interest and/or safety.

Children
Washburn Center does not knowingly solicit personal information from children or send them requests for personal information.

Security
We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information, such as credit card data, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

Washburn Center works with two third-party credit card companies: www.authorize.net and bluepay. This partner is a member of the TRUSTe program and handles all information in accordance with laws enacted to protect consumers like you.

Even though Washburn Center will take all reasonable steps to protect your personal and financial information, it cannot and does not guarantee its confidentiality or security. If you prefer, contributions can be made by calling 612.871.1454, or you can mail your donation to:

Washburn Center for Children
1100 Glenwood Avenue
Minneapolis, MN 55405

Use of “Cookies”
A cookie is a small data file that certain websites write to your computer’s hard drive when you visit them. We only use cookies to make your experience at our website more pleasant—not track personally identifiable information about you.

A cookie can’t read data off your hard drive or read cookie files created by other sites. You can refuse cookies by turning them off in your browser. If you don’t know how, use your browser’s help function. By turning cookies off, you may limit the sites you can visit.

Limitation on Liability
By using Washburn Center’s website you agree that Washburn Center, its affiliates, officers, agents, directors and employees are not liable to you for any negligence claims or causes of action arising out of or relating to the use of this website or any information you provide to Washburn Center. You expressly agree to assume the entire risk of the quality and performance of this website and the accuracy or completeness of its content.

Changes to Website and Policies
Washburn Center may change the content of its website, privacy policy statement or any other statement at any time. We encourage you to revisit the site occasionally to review updated information.

Your Acceptance of Policy
By using this site, you verify your acceptance of Washburn Center’s Internet privacy policy statement. If you do not agree to the contents of this statement, please do not use our website.

Copyright/Trademarks
All materials posted on this site are owned by Washburn Center and subject to copyright. All rights reserved. The names, trademarks, service marks and logos of Washburn Center appearing on this site may not be used in any advertising or publicity without Washburn Center’s prior consent.

Limited English Proficiency (LEP) Plan

Purpose
The purpose of this plan is to document the policies and procedures as it applies to providing meaningful access (language access) to individuals with Limited English Proficiency (LEP) while accessing services and information at Washburn Center for Children in Minneapolis, MN.

Authorities

• Title VI of the Civil Rights Act of 1964, 42 U.S.C. §2000 et seq.; 45 CFR §80, Nondiscrimination Under Programs Receiving Federal Financial Assistance through the U.S. Department of Health and Human Services Effectuation of Title VI of the Civil Rights Act of 1964.
• Office for Civil Rights Policy Guidance, Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, 68FR 47311 (2003). http://www.hhs.gov/ocr/civilrights/resources/specialtopics/lep/policyguidancedocument.html
• Department of Justice regulation, 28 CFR §42.405(d)(1), Department of Justice, Coordination of Enforcement of Non-discrimination in Federally Assisted Programs, Requirements for Translation. http://www.justice.gov/crt/grants_statutes/corregt6.txt
• Communications Services, Minnesota Status § 15.441, subd (1), (2), (3), (4). https://www.revisor.leg.state.mn.us/statutes/?id=15.441&format=pdf
• Information for persons with limited English language proficiency, Minnesota Status §256.01 subd 16. https://www.revisor.mn.gov/statutes/?id=256.01

Definitions

• Culturally appropriate services – Is the utilization or application of services, testing, and any other methodology that does not have the effect of subjecting individuals with LEP, and/or their families to discrimination because of their race, color, or national origin, or do not have the effect of defeating or substantially impairing accomplishment of the objectives of the program with respect to individuals of a particular race, color, or national origin.- 45 CFR 80.3(b)(2).

• Effective communication – In a healthcare delivery setting such as mental health, effective communication occurs when provider staff have taken the necessary steps to make sure that a person with Limited English Proficiency is given adequate information to understand the services and benefits available and receives the information and services for which they are eligible. Effective communication also means that a person with Limited English Proficiency (LEP) is able to communicate the relevant circumstances of their situation to the provider, and for the provider has access to the adequate information to do their job.
• I Speak Cards – “I Speak” Cards say both in English and target language “I need a (target language) interpreter.”
• Individual with Limited English Proficiency (LEP) – A person with Limited English Proficiency or “LEP” is not able to speak, read, write or understand the English language well enough to allow them to interact effectively with healthcare, social services agencies, and other providers.
• Interpreting – Interpreting means the oral, verbal or spoken transfer of a message from the source language into the target language. There are different modes of interpreting such as consecutive, simultaneous, sight-translation, and summarization.
• Language Block – Is a block of text that informs readers, in ten different languages, how they can get free help interpreting the information on a particular document or included as an insert in appropriate documents.
• LEP Implementation Team (or responsible individuals for compliance) – Individuals appointed by LEP, Director of operations to review LEP Implementation activities within Washburn Center for Children.
• Meaningful access – Meaningful access to programs, information, and services is the standard of access required of federally funded entities to comply with language access requirements of Title VI of the Civil Rights Act of 1964. To ensure meaningful access for individuals with Limited English Proficiency, service providers must make available to clients, patients and their families language assistance that is free of charge and without undue delay resulting in accurate and effective communication.
• Office for Civil Rights (OCR) – The Office for Civil Rights is the civil rights enforcement agency of the U.S. Department of Health and Human Services. OCR Region V is the regional office that enforces Title VI in Minnesota for health and human services agencies and providers.
• Primary languages – Primary languages are the languages other than English that are most commonly spoken by clientele as identified by Washburn Center for Children collection of demographic data. Currently there is 1 primary language: Spanish.
• Qualified Interpreter – A person who either has met training and competency requirements or who is a certified healthcare interpreter and in good standing before their certifying body, and adheres to the interpreter code of ethics as delineated in Section C and the National Code of Ethics and Standards of Practice for Interpreters in Health Care (National Council on Interpreting in Health Care –NCIHC).
• Sight translation – The verbal translation (transfer) of a written document from the source language into the target language.
• Translation – Translation means the written transfer of a message from the source language into the target language.

Methods of Providing Services to individuals with LEP

• Bilingual staff
• Interpreter services including in-person, by phone
• Document translation services.

Preferred Interpreter for appointments: Kim Tong Translation Service, Inc.

• Contracted Interpreters:
  • Kim Tong Translation Service, Inc.
  • ARCH Language Network
  • ASL Interpreting Service (ASLIS)
  • A-Z Friendly Languages
  • Language Line (phone interpreting)
  • Intelligere
• Advanced Noticed Telephone Interpreter Services: Kim Tong, Intelligere
• Unplanned/Urgent Telephone Interpreter Services: Language Line
• Video Remote Interpreting (VRI) Services: inquire to Beth Dahline, Director of Operations.

LEP Liaison & Coordinator: Beth Dahline, Director of Operations, 612-767-4867

Interpreter Services

Washburn Center for Children, without undue delay and at no cost to individuals with LEP and/or their families, provides meaningful access to information and service to all individuals with LEP and/or their families receiving services.

Translation of Documents
Washburn Center for Children contracts qualified translators or translating agencies to assist individuals with LEP in translating all vital documents, or documents needed to perform services.

Dissemination and Mandatory Training to Agency Staff , Volunteers, and Others
Washburn Center for Children is committed to providing LEP training to:

• All staff at new employee orientation during which staff will receive an LEP fact sheet, access to the Agency LEP plan as well as directions for accessing interpreter and translation services, AND
• At least once a year an in person training to all staff, volunteers, and contractors

Washburn Center for Children will keep record of those training sessions and individual attendance to training will be part of the Learning Management System at the Agency that has a tracking capacity. Record of this training will be kept for a minimum of five years and readily available during DHS audits, investigations, or any proceeding and as required by the law.

This training is to include at least the following:

• Title VI of the Civil Rights Act of 1964
• How to work effectively with interpreters, and
• Any other cultural issues related to delivery of information and services to individuals with LEP served by Washburn Center for Children.

This policy is added to the Manual of Policies and Procedures of Washburn Center for Children.

Dissemination of Language Access Information in Public Areas
Washburn Center for Children makes available to individuals with LEP:

• Notice of language access services by posting in public areas the “Language Poster”, available through DHS public Web site (https://edocs.dhs.state.mn.us/lfserver/Legacy/DHS-4739-ENG )
• “I need an interpreter” card available in ten languages and from DHS public Web site (https://edocs.dhs.state.mn.us/lfserver/Public/DHS-4374-ENG)

Annual Review of LEP Plan
Washburn Center for Children reviews annually its LEP plan to adjust or modify its contingencies based on demographic data collected by Washburn Center for Children during its delivery of information and services to individuals with LEP throughout the year.

Washburn Center for Children upon DHS request will complete and submit DHS LEP Plan review on an annual basis or as often as requested by DHS.

Collection of Data & Its Analysis
Washburn Center for Children is committed to monitor and make reasonable adjustments to comply with Title VI requirements. Washburn Center for Children will collect:

• Date of birth (DOB), gender, preferred spoken language, preferred written language, needs interpreter (Yes, No), cultural background, ethnicity, socio-economic status.

The purpose of collecting these data is to provide competent clinical services as well as for reporting purposes.

When outcomes are evaluated our data enables Washburn Center for Children to identify how any of the above factors may impact client outcomes. It also enables the Agency to identify demographic trends and changes over time.

Complaint Process:
Individuals with LEP have the right to file a formal complaint with:

• Washburn Center for Children, Associate Director of Compliance & Client Access:

Jennie Alexander
612-677-2890
jennie.alexander@washburn.org
Washburn Center for Children
1100 Glenwood Avenue, Minneapolis, MN 55405

• Minnesota Department of Human Services (DHS), Limited English Proficiency (LEP) Coordinator:

Alejandro Maldonado
651-431-4018
P.O. Box 64997
Saint Paul, MN
55164-0997
alejandro.maldonado@state.mn.us
Fax  651-431-7444
MN Relay  711 or  1-800-627-3529

• Office for Civil Rights (OCR), Region V – Chicago, IL

Celeste Davis, Regional Manager
Office for Civil Rights
S. Department of Health and Human Services
233 N. Michigan Ave., Suite 240
Chicago, IL 60601
Voice Phone (800) 368-1019
FAX 312-886-1807
TDD 800- 537-7697
http://www.hhs.gov/ocr/civilrights/complaints/index.html