Amn Healthcare Services Inc · NYSE:AMN
Amn Healthcare Services — Investor Presentation (December 2024)
55 slides from Amn Healthcare Services's investor presentation, December 2024
Slide 1: Section 1557 Readiness Workshop – Session 2
Section 1557 Readiness Workshop – Session 2 Guidance and Resources for the January and May 2025 Requirements Matt Fidler, VP Client Experience for AMN Healthcare Language Services Drew Stevens, Esq, Of Counsel with Parker Hudson Rainer & Dobbs Carla Fogaren RN, National Health Equity & Language Acce
Slide 2: Our Speakers
Our Speakers MATT FIDLER DREW STEVENS, JD CARLA FOGAREN, RN VP Client Experience Of Counsel National Health Equity & Confidential. Property of AMN Healthcare. AMN Healthcare Parker, Hudson, Rainer & Dobbs LLP Language Access Consultant 2
Slide 3: A Brief Disclaimer
A Brief Disclaimer This presentation is for general informational purposes only. Nothing contained in this presentation or said during this presentation constitutes legal advice. Confidential. Property of AMN Healthcare. 3
Slide 4: Today's Agenda
Today’s Agenda • 2025 Deadlines quick overview • Decisions Support & AI • Non-Discrimination and Telehealth • Notices of Availability of Language Services and Aux. Aids • Language Access Policies & Confidential. Property of AMN Healthcare. Procedures • Answer Questions 4
Slide 5: What do you need to do and by when?
What do you need to do and by when? § 92.10 Post Notice of nondiscrimination Within 120 days of effective date (November 2, 2024) § 92.7 Appoint a Section 1557 Coordinator Within 120 days of effective date (November 2, 2024) § 92.207(b)(1) through (5) Nondiscrimination in health For health insurance
Slide 6: What do you need to do and by when?
What do you need to do and by when? § 92.10 Post Notice of nondiscrimination Within 120 days of effective date (November 2, 2024) § 92.7 Appoint a Section 1557 Coordinator Within 120 days of effective date (November 2, 2024) § 92.207(b)(1) through (5) Nondiscrimination in health For health insurance
Slide 7: What is likely to happen now?
AN AMN WF VVealthcare What is likely to happen now?
Slide 8: Considerations for the Incoming Administration
Considerations for the Incoming Administration As before, the Trump Administration is likely to substantially revise the Biden Administration's regulation under Section 1557 of the ACA through notice and comment rulemaking. Items to consider: • The earlier revised regulation under the Trump Administ
Slide 9: A Note about the January Requirements (Insurance/Payers)
A Note about the January Requirements (Insurance/Payers) The Biden Administration's regulation includes a delayed effective date of the first day of the first plan year on or after January 1, 2025 for required changes to group health plan coverage benefit design. "OCR clarifies that any covered enti
Slide 10: Nondiscrimination in Use of Patient Care Decision Support Tools & AI
Nondiscrimination in Use of Patient Care Decision Support Tools & AI Confidential. Property of AMN Healthcare. 10
Slide 11: Nondiscrimination in Use of Patient Care Decision Support Tools & AI
Nondiscrimination in Use of Patient Care Decision Support Tools & AI (a) General prohibition. A covered entity must not discriminate on the basis of race, color, national origin, sex, age, or disability in its health programs or activities through the use of patient care decision support tools. (b)
Slide 12: Nondiscrimination in Use of Patient Care Decision Support Tools & AI
Nondiscrimination in Use of Patient Care Decision Support Tools & AI Patient care decision support tool - any automated or non- automated tool, mechanism, method, technology, or combination • GENERAL thereof used by a covered entity to support clinical decision-making in its health programs or activ
Slide 13: Nondiscrimination in Use of Patient Care Decision Support Tools & AI
Nondiscrimination in Use of Patient Care Decision Support Tools & AI Whether assessing whether "reasonable efforts" have been made to identify potential risks, HHS OCR stated that it will consider: • GENERAL PROHIBITION 1. the system’s size and resources; (Definitions And Requirements) 2. whether th
Slide 14: Nondiscrimination in Use of Patient Care Decision Support Tools & AI
Nondiscrimination in Use of Patient Care Decision Support Tools & AI • GENERAL For mitigation, HHS OCR stated that health systems are PROHIBITION encouraged to: (Definitions And Requirements) 1. Establish written policies and procedures for the use of these tools in decision-making, including govern
Slide 15: Machine Translation Definition
Machine Translation Definition Automated translation, without the assistance of or review by a qualified human translator, that is text-based and provides instant translations between various languages, sometimes with an option for audio input or output. Confidential. Property of AMN Healthcare. DEF
Slide 16: When a Review by a Qualified Human Translator is Required
When a Review by a Qualified Human Translator is Required When the text being translated… • Is critical to rights, benefits or meaningful access, • Where accuracy is essential, • Or the source document/materials contain complex, non-literal or technical language. Confidential. Property of AMN Health
Slide 17: Nondiscrimination Requirements for Telehealth
Nondiscrimination Requirements for Telehealth Confidential. Property of AMN Healthcare. 17
Slide 18: Requirements for Telehealth Services
Requirements for Telehealth Services Specific definition of "telehealth" “The use of electronic information and telecommunications technologies to support long- distance clinical health care, patient and professional health-related education, public health, and health administration. Technologies in
Slide 19: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Confidential. Property of AMN Healthcare. 19
Slide 20: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Confidential. Property of AMN Healthcare. 20
Slide 21: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Examples of Access Challenges in Telehealth: • A telehealth platform that does not support screen reader software for patients with limited vision • Telehealth platform that does not allow interpreters to join remotely • Instructions to access the
Slide 22: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Must communicate effectively with all individuals in all communication, including: • Provider Availability • Records Access • Scheduling • All communication during appointments Confidential. Property of AMN Healthcare. 22
Slide 23: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Examples of Solutions/Aids for people who are deaf or hard of hearing (DDH): • A telehealth platform that allows ASL interpreters to join calls remotely. • Telehealth platform that provides “effective” real-time captioning. • May not require patien
Slide 24: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Examples of Solutions/Aids for people who have visual disabilities: • Web-based portals that deliver screen-reader compatible recommendations • Physical therapy exercise demonstration videos that have audio descriptions. • Willingness to do consult
Slide 25: HHS OCR Guidance on Nondiscrimination in Telehealth
HHS OCR Guidance on Nondiscrimination in Telehealth Examples of Solutions/Aids for LEP Patients: • Emails or Social posts to patients that talk about Telehealth availability include a line or two (not in English) about how to get the same info in the post/email in other languages • Ensures the platf
Slide 26: Questions?
26 Confidential. Property of AMN Healthcare. Questions?
Slide 27: Legal and Regulatory Compliance
Legal and Regulatory Compliance Joint Commission/DNV/NCQA STATE MANDATED REGULATIONS AND HEALTH INSURANCE LAWS PORTABILITY AND CIVIL RIGHTS ACT ACCOUNTABILITY TITLE IV (Various) ACT (HIPAA) 1964 1996 AMERICANS WITH EXECUTIVE ORDER DISABILITIES ACT 13166 1990 2000 AFFORDABLE CARE ACT & Confidential.
Slide 28: Great Resources from the HHS and other Sources
Great Resources from the HHS and other Sources Confidential. Property of AMN Healthcare. 28
Slide 29: Great Resources from the HHS and other Sources
Great Resources from the HHS and other Sources Confidential. Property of AMN Healthcare. 29
Slide 30: Great Resources from the HHS and other Sources
Great Resources from the HHS and other Sources Confidential. Property of AMN Healthcare. 30
Slide 31: Great Resources from the HHS and other Sources
Great Resources from the HHS and other Sources Confidential. Property of AMN Healthcare. 31
Slide 32: Notices of Availability of Language Services and Auxiliary Aids
Notices of Availability of Language Services and Auxiliary Aids Confidential. Property of AMN Healthcare. 32
Slide 33: Important Resource: Pre-translated Availability Statements
Important Resource: Pre-translated Availability Statements Confidential. Property of AMN Healthcare. 33
Slide 34: Notice Requirements of Availability of Language Services & Auxiliary Aids
Notice Requirements of Availability of Language Services & Auxiliary Aids Paper size: A2 • Language: Provide in English and the top 15 languages in the state. • Font: Minimum 20-point sans serif or larger. • Availability: • Annually and upon request. • Display on the entity’s website and at prominen
Slide 35: Notice of Availability of Language Assistance Services and Auxiliary Aids and Services
Notice of Availability of Language Assistance Services and Auxiliary Aids and Services Confidential. Property of AMN Healthcare. 35
Slide 36: Examples: I Speak
Confidential. Property of AMN Healthcare. 36 Examples: I Speak
Slide 37: Notice of Availability of Auxiliary Aids
Confidential. Property of AMN Healthcare. Aids Notice of Availability of Auxiliary 37
Slide 38: Language ID Poster and Disability Accommodations
Language ID Poster and Disability Accommodations Confidential. Property of AMN Healthcare. 38
Slide 39: Written Language Access Procedures
39 Confidential. Property of AMN Healthcare. Written Language Access Procedures
Slide 40: Requirements For A Written Language Access Procedure
Requirements For A Written Language Access Procedure A covered entity must implement written language access procedures in its health programs and activities describing the covered entity's process for providing language assistance services to individuals with limited English proficiency… Confidenti
Slide 41: Requirements For A Written Language Access Procedure
Requirements For A Written Language Access Procedure A covered entity must take reasonable steps to provide meaningful access to each individual with limited English proficiency (including companions with limited English proficiency) eligible to be served or likely to be directly affected by its hea
Slide 42: Written Language Access Procedure Requirements
Written Language Access Procedure Requirements • Coordinator Information: Section § 1557 contact details. • LEP Identification: Process for employees to identify Limited • GENERAL English Proficiency (LEP) individuals. REQUIREMENTS (What to include in the policy) • Language Services: Steps to obtain
Slide 43: Written Language Access Procedure Requirements
Written Language Access Procedure Requirements What Must Be Provided? • GENERAL • Meaningful access for individuals with Limited English REQUIREMENTS (What to include in the policy) Proficiency (LEP). • Reasonable steps, including: • “REASONABLE • Provision of interpreters or written translations. S
Slide 44: Written Language Access Procedure Requirements
Written Language Access Procedure Requirements • Do not require individuals to provide their own interpreter. • GENERAL • No reliance on: REQUIREMENTS (What to include in the policy) • Minor children as interpreters, except in life-threatening emergencies when no qualified interpreter is available.
Slide 45: Interpreter vs. Translator vs. Bilingual Clinical Staff
Interpreter vs. Translator vs. Bilingual Clinical Staff Confidential. Property of AMN Healthcare. 45
Slide 46: "Qualified Bilingual Staff" Definition Change
“Qualified Bilingual Staff” Definition Change A Bilingual or Multilingual staff/provider Bilingual or Multilingual staff/providers: who has demonstrated to the covered entity: An individual who is a member of the covered entity’s workforce who is designated to provide in- 1. Proficient in speaking a
Slide 47: Utilizing an outside vendor for language assessments
Utilizing an outside vendor for language assessments • Objective in passing or failing candidates • Validity of test • Legally defensible • Cost efficient • Language availability • No repercussions • Meets legal and regulatory compliance Confidential. Property of AMN Healthcare. 47
Slide 48: Translated Materials
Translated Materials Must have repository of all translated material • Date translation Issued and language identified • Current list of ALL written translated material • Work with your vendor to create a translation portal that staff can access How do we handle Discharge Instructions? 48
Slide 49: Provision of Auxiliary Aids and Services
Provision of Auxiliary Aids and Services Communication Aids: • Qualified interpreters • Note takers, CART providers, written materials, exchange of notes, whiteboards. • Screen reader software. Hearing Assistance: • Hearing amplifiers, telephone amplifiers, assistive talking/listening devices. • Hea
Slide 50: Provision of Auxiliary Aids and Services (cont.)
Provision of Auxiliary Aids and Services (cont.) Visual Support: • Visual cue cards with pictures. • Magnification software, large-print materials, books on tape, and audio recordings. Low Vision Aids: • Qualified readers, software readers, glasses, hearing aid batteries. Other Effective Methods: •
Slide 51: Translated Cue Cards Available in 35 languages
Translated Cue Cards Available in 35 languages • Source: https://www.easternhealth.org
Slide 52: Q&A
Q&A MATT FIDLER DREW STEVENS, JD CARLA FOGAREN, RN VP Client Experience Of Counsel National Health Equity & Confidential. Property of AMN Healthcare. AMN Healthcare Parker, Hudson, Rainer & Dobbs LLP Language Access Consultant matt.fidler@amnhealthcare.com dstevens@phrd.com fogarencarla@gmail.com 52
Slide 53: Resources
Resources • Section 1557 Compliance Guide: AI & Decision Support Tools • HHS OCR Guidance to Nondiscrimination in Telehealth • SAMPLE: Written Language Access Procedures • SAMPLE: Effective Communication Procedures (For Individuals with Disabilities) • Notice of Availability of Language Access in 47
Slide 54: Post-Webinar Actions
Post-Webinar Actions Get the Slide Deck & Sign up for the Next Sec. 1557 Get in Touch / schedule a Resources Workshop (Jan 15) consult Confidential. Property of AMN Healthcare. The slide deck and all linked resources Join us for our next session taking place Current clients can reach out to their wi
Slide 55: Confidential. Property of AMN Healthcare.
www.AMNHealthcare.com/language-services Confidential. Property of AMN Healthcare. 55
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