ACCESSIBLE CUSTOMER SERVICE POLICY
MyHealth Centre is dedicated to improving accessibility to services for persons with disabilities, in accordance with the Accessibility for Ontarians Disabilities Act (AODA). If you experience any challenges with accessibility when visiting any of our clinics, please inform the clinic manager or send your comments to email@example.com.
This policy seeks to communicate standards which improve accessibility to the services of MyHealth for persons with disabilities, in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”).
The following definitions are used in this policy:
Assistive Device – is a technical aid, communication device, or medical aid that is modified or customized and used to increase, maintain, or improve the functional abilities of persons with disabilities.
Disability – as defined by AODA and the Ontario Human Rights Code is:
- any degree of physical disability, infi rmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a Service animal or on a wheelchair or other remedial appliance device;
- a condition of mental impairment or a developmental disability;
- a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols of spoken language;
- a mental disorder; or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Service Animal – as defined in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if it is readily apparent that the animal is used by the person for reasons relating to his or her disability, or if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.
Support Person – as defined in Ontario Regulation 429/07, a support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care or medical needs or with access to goods or services.
PROVIDING SERVICES TO PERSONS WITH DISABILITIES
MyHealth is committed to excellence in serving all clients, including persons with disabilities, and will carry out functions and responsibilities in the following areas:
1. Communication: MyHealth will train its Employees on how to interact and communicate with persons with various types of disabilities. Refer to the Communication Procedure for further guidance.
2. Assistive Devices: MyHealth is committed to serving clients who use assistive devices while accessing MyHealth services.
3. Support Persons: Unless there is a safety concern, persons with disabilities who require a support person are welcome to enter MyHealth locations with a support person. Written consent from the person with disability will be required when communicating confidential issues in the presence of a support person utilizing the MyHealth Consent Form.
4. Service Animals: Persons with a disability who require a service animal are welcome to enter MyHealth locations, except in areas where otherwise prohibited by law. Where service animals are not clearly identified, the owner may be required to provide pertinent documentation. In the event that an Employee or client at the location is allergic to animals, accommodations will be made.
5. Service Disruptions: MyHealth will make reasonable effort to provide notice where possible in the event of a planned or unexpected disruption in facilities or services used by persons with disabilities.
Training of MyHealth Employees
All Employees will be required to complete the Accessibility Customer Service Training. Training will be provided as soon as possible, as part of an Employee’s orientation to MyHealth, and on an ongoing basis. New hires will be required to complete this training within a 60-day period following their employment start date.
As required by Ontario Regulation 429/07, MyHealth will keep all records of training completed.
Please note: The AODA (Accessibility) Request Form can be obtained from your Manager or HRD.
INDIVIDUAL ACCOMMODATION PLAN
MyHealth Centre is committed to accommodating people with disabilities and will use the following process to identify and meet employee accommodation needs.
1. Recognizing the Need for Accommodation
Accommodation can be:
- Requested by the employee
- Identified by the employee’s supervisor
2. Gathering Relevant Information and Assessing Individual Needs
The employee is an active participant in this step.
- Information will be collected on the employee’s functional abilities, not the nature of the employee’s disability.
– The employee’s personal information, including the medical information, if any, are kept secure and dealt with in a confidential manner. It will only be disclosed to individuals who need it to perform the accommodation process.
- The employee and his/her supervisor will work together to find the most appropriate accommodation.
– A medical or other expert may be engaged at the company’s expense to help determine if/how the employee’s needs can be accommodated.
– The employee may ask a workplace representative. where applicable, to participate in the process.
3. Individual Accommodation Plan
After identifying the most appropriate accommodation(s), the details will be documented in a writen plan, including:
- What accommodation(s) will be provided
- How to make information accessible to the employee, including accessible formats and communication supports
- Employee emergency information and/or emergency response plan (if applicable)
- When the plan will be reviewed and updated
The supervisor shall provide the employee a copy of the individual accommodation plan, or written reasons for denying accommodation.
4. Implement, Monitor and Update the Plan
After implementing the accommodation plan, the employee and the supervisor will monitor and review the plan to ensure that it is effective. Formal reviews and updates will take place on the mutually agreed upon, predetermined schedule in the employee’s accommodation plan. If the accommodation is no longer appropriate, the employee and the manager will reassess the situation (step 2) and update the plan.
The accommodation plan will also be reviewed and updated if:
- The employee’s work location or position changes
- The nature of the employee’s disability changes
Please click here to download the Individual Accommodation Plan form.
MULTI-YEAR ACCESSIBLILTY PLAN
MyHealth Centre is committed to excellence in serving all clients, including persons with disabilities. We aspire to remove and prevent barriers to accessibility. MyHealth Centre administrators work with property managers and other support services to update our facilities and protocols over time, such as, the revision of the service animal policy, update of the chaperone policy, and staff training to use the TTY services for the hearing impaired. The target date for implementation of measures, policies, practices, and requirements shall be no more than 5 years after initial recognition. While the age of some of the buildings and infrastructure may not be under the control of MyHealth Centre, which may limit the type of improvement for accommodation, we will continue to communicate with patients, staff, and administrators for any accessibility needs as they may arise.
5 YEAR PLAN (2027)
- Annual review Accessibility for Ontarians with Disabilities Act (AODA) for updates
- Annual AODA training for all employees
- Maintain training records for AODA
Clinic Managers and Joint Health & Safety Committee review all Individual Accommodation Plans and determine implementation company wide or location specific accommodation. MyHealth Centre will continue to review accessibility challenges at all locations based on:
- Feedback from patients
- Individual Accommodation Plans
- Joint Health & Safety Inspections
- Site meetings
We will continue to:
- Review solutions, train, and implement
- Replace and update accommodation where feasible
- Where physical installations are required, work with landlords and facility managers to meet accessibility requirements in accordance with AODA
- While moving to new clinic locations or renovations, review accessibility requirements on building permits based on the city or region’s accessibility requirements.
- Service Kiosk/Online Registration plan will be reviewed.
All Employees will be required to complete the Accessibility for Ontarians with Disabilities Act (AODA) training. AODA training module is prompted to every employee via an email reminder upon joining and on an annual basis.
SUPPLEMENTAL PROTOCOLS & POLICIES AT MYHEALTH CENTRE
- Accessible Customer Service Policy
- Communication Procedure
- Use of Support Persons
- Feedback Procedure
This policy outlines the method to communicate with persons with disabilities in a manner that takes into account their disability and train Employees who communicate with clients on how to interact and communicate with persons with various types of disabilities.
- In accordance with the Accessible Customer Service Policy, communicate and interact with persons with disabilities in a manner that respects their dignity and independence, and provides equality of opportunity while taking into account the person’s disability;
- Engage with persons with disabilities to have a shared understanding of how best to assist them;
- Contact their manager for guidance and direction in situations where they feel they need additional support;
- Recognize that a person may have more than one disability and apply any necessary accommodations, as outlined in this procedure;
- Provide information or documentation, as required, in a format that takes into account the person’s disability and accommodates his/her need for an accessible format. The Employee and the person with a disability will agree upon the format to be used for the document or information;
- Obtain consent from the person with the disability before engaging in conversation that includes confi dential information, and ensure a Consent Form is signed by the appropriate parties when a support person acts as an intermediary. Refer to the Use of Support Persons Procedure for the Consent Form.
Upon hire, all Employees will be trained to have working knowledge and understanding of various communication methods helpful to persons with disabilities including:
- Pen and paper;
- Typing back and forth;
- Adjusting speaking style to speak more slowly or clearly;
- Electronic communication systems; and
Clients who use Assistive Devices
- Engage with the person with disability to understand how best they can help with their assistive device. For example, ask permission before pushing someone in his/her wheelchair and if conversing for a long period, sit down, if possible, to be at eye-level with the person in the wheelchair; and
- Ask permission to assist with any assistive device unless in an emergency.
Clients who have a Hearing Impairment
- Identify themselves by name and look directly at the person when communicating with him/her at all times.
- Use a normal volume to speak and be attentive to cues that the person may be having difficulty hearing the conversation. Employees may speak slightly louder or suggest moving to a quieter location;
- Explore other means of communication, such as writing or electronic. If the person reads lips, do not obstruct your face, and if possible stand directly in front of him/her. Ensure pen and paper are available for exchanging notes;
- Ensure that the person using an assistive device receives help. Ask if she/he needs assistance with the device, and support him/her to use the device. For example, a person may use communication aids/boards, hearing aids, or a personal amplifi cation device. If a service animal is present, Employees are not to pet or otherwise distract the service animal. Refer to the Use of Service Animals Procedure for further guidance; and Communicate directly with the person with the disability, rather than a support person (e.g. a sign language interpreter), if present.
Clients with Vision Loss
- Identify themselves by name when approaching the person with a disability, and speak directly to him/her in normal tones;
- Address the person by name, to ensure the person understands someone is speaking to him/her;
- Communicate directly with the person with the disability, rather than a support person, if present;
- If the person uses an assistive device (e.g. a person may use a white cane, magnifying glasses or screen magnifiers, or be accompanied by a service animal to help them interact in a situation), ask if she/he needs assistance with the device and support him/her to use the device as needed;
- Offer to read any brochure or document to a person with low vision;
- Offer assistance to guide a person, walking slightly ahead and provide information on the surroundings related to uneven ground/steps/obstacles;
- Provide specific information or direction, using terms relative to the person during verbal communication. For example, to their left or right, providing guidance on position of obstacles, distances, and change in direction;
- At the end of the interaction, let the person know when leaving the room.
Clients who have a Hearing Impairment and Vision Loss
A support person will likely accompany a client who has a hearing impairment and vision loss, or the client will have a card indicating their preference in how to communicate. Utilize the above accommodations when communicating with a client who has a hearing impairment and vision loss.
Clients with Mental Health Disabilities
- Engage with the client to have a shared understanding of how they may be of assistance to him/her, recognizing that symptoms may not always be present or she/he may be having difficulty controlling their symptoms; and
- Provide information in a clear and concise manner, listen carefully, and restate information to ensure a shared understanding of the communication.
Clients who have Intellectual or Developmental Disabilities
- Engage with the client, to have a shared understanding of how they may be of assistance when recognizing the disability is not always obvious. Ask the client to repeat any information not understood;
- Provide information in a clear and concise manner, listen carefully, and restate information to ensure a shared understanding of the communication. Provide small bits of information in simple terms at one time.
- When speaking, use plain language and avoid technical terms. Encourage the client to ask you to repeat any information they may not understand;
- Ask the person if an assistive device may help them interact in the situation. If they need assistance with the device, support them to use the device as needed. For example, a client may wish information read aloud to him/her; and
- Communicate directly with the person with the disability, rather than a support person, if present.
Clients who have Learning Disabilities
- Engage with the client to have a shared understanding of how they may be of assistance to them, recognizing various communication difficulties;
- Provide information in a clear and concise manner, listen carefully, and restate information to ensure a shared understanding of the communication;
- Break-up lengthy conversations to shorter ones, allowing the client to process the information;
- Encourage the client to ask you to repeat any information that was not understood; and
- Ask the client if an assistive device may help him/her to interact in the situation. If she/he needs assistance with the device, support them to use it. For example, a client may use pen and paper, tape recorder, computer, personal data managers, or calculator.
Clients with Physical Disabilities
- Engage with the client to have a shared understanding of how to be of assistance, recognizing she/he may take longer to accomplish a task or have a particular way of helping themselves;
- Ask if the client needs help with any assistive device, and provide support as needed. For example, a client may use a wheelchair, scooter, crutches, cane, walker, or personal oxygen devices;
- If needed, assist the client with handling brochures or documents and reaching for items when required; and
- Ask permission to move a client’s assistive device unless in an emergency-situation.
Clients with Speech or Language Difficulties
- Engage with the person to have a shared understanding of how to be of assistance, recognizing the client may take longer to communicate;
- Ask questions that require one or two word answers and do not interrupt the client when they are responding; and
- Ask if they need assistance with their assistive device and support them to use the device as needed. For example, a person may use pen and paper, computer, communication board, or speech generating device.
Serving Clients who use a Support Person
- Refer to the Use of Support Persons Procedure
- Ensure persons with disabilities have access to their support person; and
- Understand and recognize circumstances where a support person will be required to ensure health and safety and communicate this need to the person with the disability.
USE OF SUPPORT PERSONS PROCEDURE – AODA
This policy outlines Company’s commitment to allowing persons with disabilities who require use of a support person to enter MyHealth locations, provided they do not pose safety concerns, and complete a consent form where required.
Persons with disabilities who are accompanied by a support person have the right to have their support person accompany them while accessing services at MyHealth. Support persons are welcome in all areas of the clinic except where excluded by law for health and safety or privacy reasons, such as any area for Employee use only or any area where biohazard or radiation exposure occurs. Where a support person is excluded by law, MyHealth will explore alternative ways for the person with disabilities to access its services.
Support Persons: In relation to a person with a disability, a support person is a person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods or services.
Eviction or Exclusion
A support person may be evicted, excluded, or separated from the client if his/her actual behaviour poses a direct threat to the health or safety of others, or if they refuse to sign the required Consent Form (Appendix A).
Refer to the Communication Procedure for further guidance on communicating with clients who use a support person.
Waiver of Rights
If the client provides consent for the support person to be present as it relates to personal health information being shared, both the client and support person must sign the Consent Form.
If the support person is informed of the risks related to being present during a procedure that may pose some risk (i.e., an x-ray), this consent must be included on the Consent Form, and a copy must be provided to the HR department.
CHAPERONE, SUPPORT PERSON + PERMISSIONS POLICY
MyHealth Centre allows patients to have a support person and/or chaperone present during procedures in order to provide support, either emotional or physical, to any patient and to protect the technologist/physician against allegations of improper behavior during examinations.
Chaperone + Support Persons
If a patient should wish, MyHealth can provide an additional staff member to be present while undergoing the examination when feasible. Alternatively, a friend or family member can accompany a patient in the examination room. The applicable waiver must be signed by all non-employees and scanned into the patients encounter in Velox.
Technologists should be informed of the need for a chaperone/support person before the examination starts.
In the event that the clinic is unable to provide the patient with a chaperone, patients will be given the option of rebooking for a new date/time before leaving the facility.
Note: A waiver/form is not required for any patient under the age of 16 who has a parent/guardian present.
For the safety of clinic staff, a technologist is able to request that a peer chaperone the examination in case additional support is required. Notes must be made on the worksheet to reflect this.
Pregnant persons are not permitted to be chaperones for any procedures involving radiation exposure.
Applicable PPE must be available for use – particularly proper lead shielding devices for X-ray.
At times relatives, friends or other identified individuals may be permitted into the exam room. Circumstances may vary and are reviewed on a case by case basis by the technologist (i.e. obstetrical show and tell). In these events, the permitted person(s) are required to sign the applicable waiver.
** In the event that the presence of a support person, chaperone, or other is requested during the exam or post check in procedure, the technologist can enter an encounter note in the PACS/EMR in lieu of the waiver.
AGE OF CONSENT
MyHealth Centre recognizes that age of the patient to consent is very important. Commonly, the accepted age of consent to accept/deny any treatment/procedure is 16yrs. However, the capacity to consent is not only age-related.
Should the technologist deem the patient not capable, the procedure can be denied and rescheduled.
If required/appropriate, a minor is permitted to consent to treatment/procedure so long as the Physician/ healthcare provider can determine the minor is capable of understanding the information regarding the treatment/procedure (i.e., pregnancy).
The patient must be able to understand the reasonably foreseeable consequences of a decision or lack of a decision. In the case that patient is not capable of understanding the capacity with respect to the procedure/treatment, a substitute decision maker (parent/guardian) must be present. The procedure can be denied and re-booked with proper notes documented to reflect the situation.
Note: This procedure applies to adults and seniors as well where applicable.
This policy provides clarity and direction with regard to the actions that MyHealth will take if a client, visitor or Employee expresses a concern, or provides comments on access to services.
MyHealth has outlined the following procedure for Employees to follow:
- All feedback will be reviewed and forwarded to the appropriate Manager/Management member Employee/ Department for follow-up;
- Where possible, complaints will be addressed immediately by Employees at the location, however; some complaints may require more eff ort to address, and must be reviewed for action;
- Clients can expect acknowledgement of verbal/telephone/email feedback within three (3) business days, and within 30 business days of the receipt of a mailed complaint;
- In some cases, it may not be possible or appropriate to acknowledge feedback, for example, if the client wishes to remain anonymous, or indicates that he/she does not want to receive an acknowledgment;
- The acknowledgement will indicate when the matter will be addressed and when the client will be notifi ed of the outcome;
- MyHealth will follow up on any actions arising from the feedback and the timeframe for implementation will be provided as part of the notifi cation of outcome;
- Feedback/response will Endeavour to be in a format that is accessible to the complainant.
Feedback can be communicated in the following ways:
Feedback may be provided by contacting the Patient Care Representative at the clinic where the client received services. Patients may also provide their feedback through the automated survey conducted by MyHealth.
Feedback may be provided by sending an email to firstname.lastname@example.org
Feedback can be mailed to the Head Offi ce.
Feedback may be provided to the Employees at the clinic where the client received services. This feedback should be forwarded to the Clinic Manager.
Via Referring Physician
Patients may also provide their feedback through their Referring Physicians.