LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  POLICY 200.09 Culturally and Linguistically Inclusive Services
 
Policy Category:  Clinical  
Distribution Level:  Directly Operated and Contractors  
Responsible Party:  Anti-Racism, Diversity, and Inclusion (ARDI) Division: Development, Engagement, and Mobilization Unit  
 
Approved by Curley L. Bonds, MD, Chief Medical Officer, on Mar 13, 2024
 
I.  PURPOSE
 
This policy establishes Los Angeles County Department of Mental Health (DMH/Department) standards for participation, implementation, and compliance with federal and State regulations regarding cultural and linguistic competence.
 
This policy ensures that culturally and linguistically appropriate, effective, and equitable services are provided at all points of entry in the Department. 
 
This policy fosters a collective sense of shared responsibility for the implementation of culturally and linguistically responsive interventions that address health inequities among all staff from directly-operated, contracted, and administrative programs.
 
Contracted agencies shall develop an internal policy and associated procedures that are consistent with their organizational practices and meet the requirements set forth in this policy.

 
II.  DEFINITIONS
 
Cultural Competence Plan Requirements (CCPR): Requirements enforced by the California Department of Health Care Services (DHCS) to provide a framework for the planning, implementation, and evaluation of services with the goal of eliminating cultural, linguistic, racial, and ethnic mental health and substance use disorder disparities.  The requirements are organized under eight specific areas or criteria (CR):
  • CR 1: Commitment to Cultural Competence
  • CR 2: Updated Assessment of Service Needs
  • CR 3: Strategies and Efforts for Reducing Racial, Ethnic, Cultural, and Linguistic Mental Health Disparities
  • CR 4: Client/Family Member/Community Committee
  • CR 5: Culturally Competent Training Activities
  • CR 6: County’s Commitment to Growing a Multicultural Workforce
  • CR 7: Language Capacity
  • CR 8: Adaptation of Services
(California DMH Information Notice 10-02, Enclosure 1)
 
Cultural Competency Committee (CCC): Committee that serves as an advisory group for the infusion of cultural competency in all DMH operations. Administratively, the CCC is housed within the Office of Administrative Operations - Cultural Competency Unit (CCU). Per DHCS Cultural Competence Plan Requirements, all Counties are mandated to have an established committee to address cultural issues and concerns with representation from different cultural groups. The CCC membership includes the cultural perspectives of consumers, family members, advocates, peers, staff from directly-operated (DO) providers and legal entities/contracted providers, and community-based organizations. The CCC advocates for the needs of all cultural and linguistic groups. Additionally, the CCC considers the expertise from the Service Areas’ clinical and administrative programs, front line staff, and management essential for sustaining the mission of the Committee.

Cultural Identity: Refers to identification with, or sense of belonging to, a particular group based on various cultural categories, including but not limited to race, ethnicity, gender, language, sexual orientation, spiritual beliefs, etc. Cultural identity is constructed and maintained through the process of sharing collective knowledge such as traditions, heritage, aesthetics, norms and customs.  As individuals typically affiliate with more than one cultural group, cultural identity is complex and multifaceted.  (Adapted from the Center for Intercultural Dialogue)
 
Cultural Humility: A lifelong process of self-awareness, self-reflection, and self-critique with the goal of identifying preconceptions, addressing power imbalances, striving to respect any differences while providing health care services, and developing partnerships with communities. (Alsharif, N.Z. PharmD, PhD. 2012, American Journal of Pharmaceutical Education, Cultural Humility and Interprofessional Education and Practice: A Winning Combination)
 
Culture: The integrated pattern of thoughts, communication, actions, customs, beliefs, values, and institutions associated, wholly or partially, with racial, ethnic, or linguistic groups, as well as religious, spiritual, biological, geographical, or sociological characteristics.  Elements of culture include: age, country of origin, degree of acculturation, educational level obtained, family and household composition, gender identity, sexual orientation, health practices, physical ability or limitations, cognitive ability or limitations, race and ethnicity, language, religious and spiritual beliefs, and socio-economic status, among others.  (CLAS in Health Care, April 2013)
 
Disparities: A type of health difference/outcome that is closely linked with social, economic, and/or environmental disadvantage which result in worse health or greater health risks than more advantaged social groups.  (Center for Medicare Advocacy)
 
Ethnic Services Manager (ESM): The designated County person responsible to align Department’s response to the local, State, and Federal cultural competence requirements; development and implementation of policies and procedures pertinent to cultural competence, tracking of service utilization outcomes; and promoting inclusion of cultural and linguistic competence in departmental practices, policies with the goal of increasing health equity and decreasing mental health disparities.

Equity: According to the World health Organization, equity is the absence of avoidable or remediable differences among groups of people, whether those groups are defined as socially, economically, demographically, or geographically; equity is the process and equality is the outcome (see the graphic below). Equity focuses on justice, recognizes 
the need for justice and fairness within the procedures and processes of institutions or systems, as well as in their distribution of resources. It is an intentional process that strives to be fair and impartial and begins by acknowledging that advantages and barriers exist. Resolving equity issues requires an understanding of the root causes of outcome disparities within our society. Equity addresses these disparities and makes a commitment to correct structural imbalance, allowing equal access, power, voice, opportunity, and welcome for all. (JHM Office of Diversity and Inclusion Fast Facts Definition Sheet and DEI Mission)

Gender Identity: A person’s deeply held core sense of self in relation to gender. Gender identity does not always correspond to sex assigned at birth. People become aware of their gender identity at many different stages of life, from as early as 18 months and into adulthood. Gender identity is a separate concept from sexuality (see Sexual Orientation) and gender expression. 

Gender Expression: The manner in which a person communicates about gender to others through external means such as clothing, appearance, or mannerisms. This communication may be conscious or subconscious and may or may not reflect their gender identity or sexual orientation. While most people’s understandings of gender expressions relate to masculinity and femininity, there are countless combinations that may incorporate both masculine and feminine expressions, or neither, through androgynous expressions. All people have gender expressions, and an individual’s gender expression does not automatically imply one’s gender identity. 
 
Health Inequities: Differences in health status that occur among population groups defined by specific characteristics.  They mostly result from inequalities in the distribution of the underlying determinants of health across populations. (Reducing Health Disparities – Roles of the Health Sector: Recommended Policy Directions and Activities)
 
Implicit Bias: Subconscious and unintentional biases are likely formed by associations in the brain that link two ideas together (i.e., a group of people with a trait), through early experiences, affective experiences, and learned cultural perspectives.  Implicit biases allow individuals to easily understand and interact with their world, especially in uncertain situations. (Royer, C., Hido, D., & Slotnick, M. 2010, Defining Implicit Bias, Cornell University Law School Social Science and Law)
 
Individual Cultural Competence: A set of attitudes, knowledge, and skills that enable the person or individual to interact effectively in cross-cultural situations.  (Cross, T.L., Bazron, B.J., Dennis, K.W., and Issacs, M.R. 1989, Towards a Culturally Competent System of Care, Georgetown University Child Development Center, CASSP Technical Assistance Center)

Inclusion: 
Inclusion is an intentional effort to transform the status quo by creating opportunity for those who have been historically marginalized. An inclusion focus emphasizes outcomes of diversity rather than assuming that increasing the amount of diversity of people automatically creates equity in access/opportunity, or an enhanced organizational climate. Inclusion begins with the needs, wants, and quality of life of the historically minoritized population rather than the historically privileged (YWCA Social Justice Glossary).

Language Assistance Services: Refers to the provision of translation and Interpreter Services, including American Sign Language (ASL) and other types of communication accommodations such as closed captioning in real time.
 
National Standards for Culturally and Linguistically Appropriate Services (CLAS):  A set of 15 standards developed by the United States Department of Health and Human Services Office of Minority Health to advance health equity, improve quality, and help eliminate health care disparities by providing a framework for individuals and health care organizations to implement culturally and linguistically appropriate services.  Overall, the CLAS Standards specify that health care organizations are federally required to provide 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. (CLAS in Health Care, April 2013)
 
Organizational Cultural Competence: The existence of policies, procedures, practices, and organizational infrastructure to support the delivery of culturally and linguistically sensitive and appropriate health care services where culture is broadly defined. (Cross, T.L., Bazron, B.J., Dennis, K.W., and Issacs, M.R. 1989, Towards a Culturally Competent System of Care, Georgetown University Child Development Center, CASSP Technical Assistance Center)
 
Social Determinants of Health: Refers to the collective impact on health derived from each person’s biology and genetics; health practices; access to, utilization and quality of health services; social factors; geography and neighborhood; exposure to stress; and the environment. (Office of Disease Prevention and Health Promotion. Healthy People 2020)
 
Underserved Communities: Refers to communities that experience disadvantages, disenfranchisement, or marginalization due to being geographically isolated, having a family income below 200% Federal Poverty Level, lacking medical insurance, having limited English language proficiency, and lacking familiarity with or accessibility to the health care system among other reasons. (U.S. Department of Health and Human Services)

Additional Terms Related to Cultural Competence:
  • Cultural appropriateness, awareness, congruence, diversity, humility, knowledge, pluralism, proficiency, responsiveness, security, safety, and sensitivity
  • Intercultural effectiveness, interactivity, readiness, sensitivity, adjustment
  • Multiculturalism
  • Transculturalism
  • Cross-cultural competencies
  • Equity
     
III. POLICY
 
DMH embraces the cultural backgrounds and cultural identity of constituents associated with race/ethnicity, national origin, language preference, literacy and communication needs, sexual orientation, gender identity, socioeconomic status, degree of physical and mental ability or disability, religious beliefs, and life-style choices, among others. (CCPR CR 1; CLAS Standards 1 and 7)
 
DMH addresses cultural and linguistic competence at all levels of the system of care such as policy and procedures, operations, service delivery, training and quality improvement activities. (CCPR CR 1, 3, 5, and 8; CLAS Standards 2, 4, and 9)
 
DMH responds to the linguistic needs of constituents, within each Service Area and across the system of care, ensuring that language assistance services are provided by certified bilingual employees or qualified language translation and interpretation vendors. (CCPR CR 6 and 7; CLAS Standards 5 and 7)
 
DMH programs incorporate cultural and linguistic competence in service planning, delivery, monitoring, evaluation, and quality improvement strategies to address health inequities, eliminate disparities, and decrease the stigma associated with mental health services. (CCPR CR 3; CLAS Standard 5)
 
DMH implements the CCPR and CLAS Standards as means to sustain an infrastructure supportive of the staff’s individual cultural competence and the organizational cultural competence of the system in providing mental health services that address the cultural and language needs of underserved communities. (CCPR CR 1-8; CLAS Standard 1)
 
DMH collaborates with stakeholders, community organizations and constituents to implement interventions that are culturally and linguistically inclusive. (CCPR CR 1; CLAS Standards 9, 13, and 15)
 
DMH allocates funding for cultural competence activities such as language translation and interpreter services, training and skill development for staff, organizational assessments, community-specific strategies to reduce disparities and grievance and appeal resolution processes, among others. (CCPR CR 1; CLAS Standards 1, 2, 4, 9, 10, 12, and 14)

 
IV.  PROCEDURES
 
Procedures - Culturally and Linguistically Inclusive Services
 
V.  AUTHORITIES
 
VI. ATTACHMENTS
 
APA Division 45: Society for the Psychological Study of Culture, Ethnicity, and Race
Cultural Competency and Patient Safety by the Agency for Healthcare Research and Quality
DSM-5 Cultural Formulation Interview project
National Culturally and Linguistically Appropriate Services Standards: Think Cultural Health
National LGBTQIA+ Health Education Center
Sexual and Gender Diversity: DMH Practice Parameter, Special Considerations - 02