Non-Discrimination Policy

(Including California State Law Compliance)

1. Policy Statement

Comfort Homesake is a nonprofit community health care organization committed to equitable access and inclusion. We strictly prohibit discrimination, harassment, and retaliation in all aspects of our operations, in accordance with both federal and California state laws, including but not limited to the California Fair Employment and Housing Act (FEHA), the Unruh Civil Rights Act, the Ralph Civil Rights Act, and the Americans with Disabilities Act (ADA). We uphold every individual’s right to dignity, respect, and equitable treatment, whether they are receiving services, applying for employment, volunteering, or interacting with the organization in any capacity.

2. Scope

This policy applies to all Comfort Homesake employees, contractors, interns, volunteers, patients, clients, program participants, board members, and any other individuals engaged with the organization.

3. Protected Categories

In compliance with California law and federal regulations, Comfort Homesake prohibits discrimination, harassment, and retaliation on the basis of, including but not limited to: race, color, ancestry,  national origin (including language use and immigration status) religion or creed, age (40 and older for employment), physical or mental disability, medical condition (including cancer or genetic characteristics), genetic information, marital status, sex, gender, gender identity, gender expression, sexual orientation pregnancy, childbirth, breastfeeding, or related medical conditions, military and veteran status, citizenship status, primary language, socioeconomic status, and any other classification protected under federal, state, or local law.

4. Commitment to Equal Access

Health Care and Community Services Comfort Homesake delivers health care and community-based services based solely on individual need. No individual shall be denied participation in, or be subjected to discrimination in, any program or activity on the basis of the characteristics listed above.

Employment and Volunteer Practices All employment decisions are made in accordance with the California Fair Employment and Housing Act (FEHA). Equal opportunity applies to recruitment, hiring, training, promotion, discipline, and all other employment practices.

Public Accommodations Under the Unruh Civil Rights Act, all persons are entitled to the full and equal accommodations, advantages, facilities, privileges, or services of Comfort Homesake, regardless of any protected characteristic.

5. Reasonable Accommodations

Consistent with the ADA and California law, Comfort Homesake will provide reasonable accommodations for individuals with disabilities, religious observances, or language needs. Requests should be made to Marilyn Ababio, Managing Director (info@comforthomesake.com or 213-887-1152).

6. Complaint Procedure

Anyone who believes they have experienced or witnessed discrimination should report it immediately to Marilyn Ababio. All complaints will be investigated promptly and confidentially. Retaliation is strictly prohibited.

Confidentiality & Privacy Policy

1. Purpose

In compliance with the Older Americans Act and Older Californians Act, Comfort Homesake is committed to protecting the confidentiality, privacy, and dignity of all clients, caregivers, staff, and volunteers.

2. Scope

This policy applies to all staff, interns, contractors, and volunteers who handle client information—whether written, verbal, or electronic.

3. Confidentiality Standards

• Client Records: All records (intake, assessments, surveys) are confidential.
• Limits: Records are kept confidential except for mandatory reporting of elder/ dependent adult abuse.
• Verbal Information: Shared only on a “need-to-know” basis.
• Electronic Information: Stored in password-protected platforms (e.g., Podio, secured email).
• Third-Party Access: No information released without written consent unless required by law.

4. Privacy Practices

Clients have the right to know what information is collected. Only necessary data is collected. Participation in surveys or contribution programs is optional and does not affect eligibility.

5. Safeguards

Physical files are in locked cabinets. Electronic records are encrypted. Record retention is based on CDA requirements.

6. Breach of Confidentiality Unauthorized disclosure results in corrective action. Affected clients will be notified in compliance with CDA and state requirements.

Voluntary Contribution & Share-of-Cost Policy

1. Purpose

This policy ensures compliance with California Department of Aging (CDA) requirements regarding voluntary contributions and share-of-cost (SOC) practices.

2. Voluntary Contributions

Participants will be given the opportunity to voluntarily contribute. Contributions are completely voluntary; refusal to contribute will not affect eligibility for services. Contributions are used exclusively to expand or enhance services.

3. Share-of-Cost (SOC)

SOC refers to the portion of service costs participants are responsible for, as determined by Medi-Cal or state/federal guidelines. Participants will be informed of obligations prior to receiving services.

4. Accountability & Non-Discrimination

Contributions are handled confidentially. No person shall be denied service because of unwillingness or inability to contribute. Services are provided equitably without coercion.

Grievance Policy

1. Purpose

This policy outlines procedures for receiving, investigating, and resolving grievances raised by patients, staff, or stakeholders to ensure complaints are addressed without retaliation.

2. Definition of a Grievance

A formal complaint concerning quality of care, staff behavior, privacy violations, discrimination, or organizational policies.

3. Policy Principles

• Confidentiality: Handled with discretion.
• Timeliness: Acknowledged within 5 business days.
• Non-Retaliation: Protection for those filing in good faith.

4. Grievance Process

Grievances can be submitted via email, letter, online form, or phone. The process includes Acknowledgment (5 days), Investigation, and Resolution (written response within 15-30 business days). Appeals may be requested within 10 business days of the decision.

Conflict of Interest Policy

1. Purpose

To ensure that the interests of Comfort Homesake are not compromised by personal, financial, or other interests of its officers, directors, employees, or volunteers.

2. Policy & Disclosure

Individuals must avoid situations where personal interests conflict with the organization. Potential conflicts must be disclosed promptly in writing to a supervisor or board chair.

3. Decision-Making

When a conflict is disclosed, the individual will not participate in related decisions. The matter will be reviewed by an independent party or committee, and actions will be documented.

5. Compliance

Failure to disclose a conflict may result in disciplinary action, including termination. All covered individuals must sign an acknowledgment of this policy.