Earn CEU credit Cathy Garrey, Connect with your - Health Care ...

which ensures that the understanding of an
issue/area of concern is complete. 6 The elements
of a finding are comprised of Criteria,
Condition, Cause, Effect, and Recommendation
(CCCER).
Definitions
Criteria - defines the what should be and
include laws, regulations, contracts, grant
agreements, standards, measures, expected
performance, and so on.
Condition - describes what is or the current
situation.
Cause - refers to the why or an explanation
for the current situation, which may be due
to such factors as lack of or poorly designed
policies and procedures or incomplete or
incorrect implementation.
Effect - describes what will happen or
the impact and spells out the discrepancy
between the criteria (what should be) versus
the condition (what is).
Recommendation - refers to what will
be done or what action(s) will be taken to
correct the situation.
To provide an example, of how the CCCER
approach may be applied to the CLAS standards,
we present the following hypothetical
situation utilizing Standard 7:
You are the manager of one of seven
outpatient clinics that are part of a large
hospital. The Chief Operating Officer (COO)
of the hospital has tasked all clinic managers
with determining whether each of the clinics
are meeting CLAS standards. The COO
has provided you with verbal and written
instructions on how to utilize CCCER and
has asked that you start your assessment with
Standard 7.
Criteria (what should be)
Standard 7 (Mandate)
Health care organizations must make
available easily understood patient-related
materials and post signage in the languages
of the commonly encountered groups and/or
groups represented in the service area.
Condition (what is)
After reviewing patient data, you determine
that your patient population consists of a
large number of recent immigrants from the
Philippines and Korea. But, you notice that
all patient-related materials (e.g., consent
forms, conflict and grievance procedures,
informational/educational brochures) are
available only in English.
Cause (why this happened)
You and your staff were unaware that these
materials were mandated by the federal government.
The hospital administration had not
provided any guidance in this area. Because
some of your staff are bilingual and have been
able to converse in the native languages of the
patients, there was an assumption that this
was sufficient.
Effect (why this matters)
Not only is the clinic out of compliance with
a federal mandate, more importantly, it has
not been culturally competent or sensitive
to its patients’ needs. A patient may have
consented to a procedure or a payment
plan without fully understanding what was
actually involved. This puts the clinic under
potential legal and/or fiscal liability.
Recommendation (what will be done)
You immediately report your finding to the
hospital COO and recommend that you
and your staff be provided with cultural
competency training with a focus on CLAS
standards. You also request a more detailed
needs assessment to determine exactly what
patient-related materials and signage are
needed, and in what languages, to properly
assist your patient population.
The above scenario simplifies the complexities
faced when trying to deal with cultural competency
issues. However, utilizing CCCER is
a good starting point and serves as a means to
identify potential risk areas without overwhelming
those tasked with ensuring cultural
competency compliance. This should not
replace a comprehensive organizational assessment,
but once again, can serve as a basis for
such an endeavor. Cultural competency will
continue to grow in significance. What the
federal government now deems as guidelines
and suggestions, may soon become mandates.
If you have already, or are planning to, assess
cultural competency in your organization,
please contact me (mariachu@hawaii.edu)
and let me know what methods you have
used or are planning to use. n
1 Brannigan, M.C. 2008. Connecting the dots in cultural competency:
Institutional strategies and conceptual caveats. Cambridge Quarterly of
Healthcare Ethics, 17: 173-184.
2 Beamon C, Devisetty V, Forcina Hill JM, et al: A Guide to Incorporating
Cultural Competency into Medical Education and Training.
December 2005, National Health Law Program.
3 http://www.qsource.org/uqiosc/CLASGuide.pdf. Accessed 7/1/08.
4 http://www.qsource.org/uqiosc/CLAS_Standards_Crosswalk_v3.pdf.
Accessed 7/1/08.
5 http://www.omhrc.gov/templates/browse.aspx1v1=2&1v1ID=15.
Accessed 7/2/08.
6 United States Government Accountability Office. July 2007. Government
Auditing Standards, July 2007 Revision. Also available online at:
http://www.gao.gov/govaud/ybk01.htm.
Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
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October 2008