Non-Discrimination Policy

Helix BioMedical complies with applicable federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, sex, sexual orientation, gender identity, religion, genetic information, veteran status, or marital status. This policy applies to all programs, services, and activities provided by Helix BioMedical, including clinical care, mobile medical missions, telehealth services, educational programs, bioinformatics tools, and charitable programs. This Notice is provided pursuant to Section 1557 of the Patient Protection and Affordable Care Act (42 U.S.C. 18116); Title VI of the Civil Rights Act of 1964; Section 504 of the Rehabilitation Act of 1973; the Age Discrimination Act of 1975; Title II of the Americans with Disabilities Act of 1990; and the Genetic Information Nondiscrimination Act of 2008.

1. Non-Discrimination Statement

Helix BioMedical does not exclude, deny benefits to, or otherwise discriminate against any person in admission to, participation in, or receipt of services or benefits of any of our programs and activities, whether carried out directly or through a contractor or any other entity with which we arrange to carry out programs and activities. This applies to all protected categories under applicable federal and state law.

We believe that every human being is created with inherent dignity and worth. As a faith-based healthcare ministry, our commitment to non-discrimination is rooted not only in legal obligation but in our core values of justice, compassion, and unconditional service to all people. We actively work to identify and remove barriers to healthcare access -- whether physical, linguistic, financial, cultural, or administrative -- so that all individuals receive equitable treatment and outcomes.

Our non-discrimination commitment covers all aspects of our operations, including: patient intake, registration, and scheduling; access to and use of all facilities and programs; assignment to providers and staff; quality and scope of clinical services delivered; participation in educational programs and training; access to telehealth and digital health tools; billing and financial assistance programs; and employment practices (governed separately by applicable employment law).

2. Title VI of the Civil Rights Act of 1964

Under Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d), we do not discriminate based on race, color, or national origin in any program or activity receiving federal financial assistance. Title VI applies to all of our federally funded programs and activities, including any programs receiving grants, contracts, or other federal support.

Title VI prohibits both intentional discrimination and practices that have a disparate adverse impact on persons based on race, color, or national origin, even where no discriminatory intent exists. We conduct regular reviews of our policies, procedures, and outcomes data to identify and remedy any practices that may have a disparate impact on patients or students of a particular race, color, or national origin.

Title VI also requires us to take reasonable steps to provide meaningful access to persons with limited English proficiency (LEP). See Section 6 of this Policy for a full description of our language access services.

3. Section 1557 of the Affordable Care Act

Section 1557 of the Patient Protection and Affordable Care Act (42 U.S.C. 18116) is the first federal civil rights law specifically prohibiting discrimination in health programs and activities. Section 1557 prohibits discrimination on the basis of race, color, national origin (including limited English proficiency), sex, age, and disability in any health program or activity that receives federal financial assistance from the U.S. Department of Health and Human Services, is administered by HHS, or is established under Title I of the ACA.

3.1 Sex Discrimination

Under Section 1557, discrimination "on the basis of sex" is construed broadly and includes discrimination based on pregnancy, childbirth, and related conditions; sex stereotyping; and, consistent with applicable legal interpretations, gender identity and sexual orientation. We do not deny or limit healthcare services based on sex, including gender-affirming care, reproductive healthcare, or services related to pregnancy and childbirth.

3.2 Compliance Review

We are committed to staying current with regulatory guidance and judicial interpretations of Section 1557. We review our policies and practices when regulatory updates are issued and implement required changes in a timely manner. We designate a Section 1557 Coordinator responsible for ensuring ongoing compliance.

4. Americans with Disabilities Act and Section 504

4.1 Americans with Disabilities Act (ADA)

Title II of the Americans with Disabilities Act (42 U.S.C. 12101 et seq.) prohibits discrimination against qualified individuals with disabilities in all programs, services, and activities. We are committed to providing individuals with disabilities full and equal access to all of our services. We will make reasonable modifications to our policies, practices, and procedures when necessary to afford people with disabilities equal access, unless the modification would fundamentally alter the nature of the service or program.

4.2 Section 504 of the Rehabilitation Act

Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794) prohibits discrimination based on disability by programs and activities receiving federal financial assistance. A person is considered to have a disability under Section 504 if the person has a physical or mental impairment that substantially limits one or more major life activities, has a record of such impairment, or is regarded as having such an impairment. We do not discriminate against any person who meets this definition in the provision of healthcare or educational services.

4.3 Physical Accessibility

Our facilities are designed and maintained to be physically accessible to individuals with disabilities, including those using wheelchairs, walkers, and other mobility aids. Our Mobile Clinic vehicles are equipped with accessible entry systems to the extent practicable. We conduct regular accessibility audits and address identified barriers promptly. If you encounter a physical barrier at any of our facilities, please inform our staff so that we may provide assistance and address the barrier.

4.4 Effective Communication

We take all steps necessary to ensure effective communication with patients with disabilities, including patients who are deaf, hard of hearing, blind, or have low vision. We provide, free of charge: qualified sign language interpreters (including ASL and tactile interpretation for deaf-blind patients); video remote interpreting services; written materials in accessible electronic formats; large-print documents; audio recordings of written materials upon request; and screen-reader-compatible digital content. We do not require patients to bring their own interpreter or to use a family member or companion as an interpreter, except in emergency situations where an interpreter cannot be arranged in time.

5. Age Discrimination Act of 1975

Under the Age Discrimination Act of 1975 (42 U.S.C. 6101 et seq.), we do not discriminate based on age in our federally assisted programs and activities. We provide services to individuals of all ages, from infants and children to elderly adults, without placing unreasonable restrictions based on age. We recognize that some health programs are designed for specific age groups (such as pediatric care or geriatric care), and such age-based distinctions are lawful where they are reasonably necessary to the normal operation of the program or activity.

We are aware of and address the risk of implicit bias against elderly patients in clinical settings, including under-treatment of pain, dismissal of symptoms as "normal aging," and barriers to participation in certain programs. We include age bias awareness in our staff training programs and incorporate equity considerations into our clinical quality improvement activities.

6. Language Access Services

6.1 Free Language Assistance

Helix BioMedical provides free language assistance services to individuals with limited English proficiency (LEP). Consistent with guidance from the U.S. Department of Health and Human Services, we assess the language needs of our patient population and take reasonable steps to provide meaningful access to all services. We do not charge for language assistance services, and we do not reduce or delay the quality of care or services to individuals based on their need for language assistance.

ATTENTION: If you speak a language other than English, language assistance services, free of charge, are available to you. Call (702) 825-0288.

6.2 Interpreter Services

We provide access to qualified medical interpreters for clinical encounters, including in-person interpreters for scheduled visits, telephonic interpretation services for unscheduled or urgent encounters, and video remote interpretation for telehealth visits. We maintain a roster of qualified interpreters in the languages most commonly spoken by our patient population and have access to telephone interpretation services covering more than 200 languages. Interpreters used in clinical settings are trained in medical terminology and in the ethical standards applicable to medical interpretation, including the obligation to interpret completely and accurately without editorializing.

6.3 Translated Documents

We translate vital documents -- including patient intake forms, consent documents, healthcare instructions, discharge summaries, and this Non-Discrimination Notice -- into languages spoken by a significant portion of our patient population. A document is considered "vital" if it contains information that is critical for receiving services or understanding your rights. You may request translated versions of vital documents by contacting us at [email protected] or (702) 825-0288.

6.4 Language Notice

• Spanish: ATENCION: si habla espanol, tiene a su disposicion servicios gratuitos de asistencia linguistica. Llame al (702) 825-0288.
• Chinese: (702) 825-0288
• Vietnamese: CHU Y: Neu ban noi Tieng Viet, co cac dich vu ho tro ngon ngu mien phi danh cho ban. Goi so (702) 825-0288.
• Tagalog: PAUNAWA: Kung nagsasalita ka ng Tagalog, maaari kang gumamit ng mga serbisyo ng tulong sa wika nang walang bayad. Tumawag sa (702) 825-0288.
• Korean: (702) 825-0288
• Arabic: (702) 825-0288

7. Disability Accommodations and Modifications

7.1 Requesting Accommodations

Individuals with disabilities who need a reasonable accommodation to participate in our programs or access our services should contact our Civil Rights Coordinator at [email protected] or (702) 825-0288 as early as possible before the scheduled service or activity. We will engage in an interactive process to identify effective accommodations and implement them in a timely manner.

7.2 Service Animals

We permit service animals, as defined by the ADA, in all areas of our facilities where patients and the public are normally allowed. A service animal is a dog (or, in limited circumstances, a miniature horse) that is individually trained to perform work or tasks for the benefit of an individual with a disability. We may ask only two questions to determine whether an animal is a service animal: (1) Is this a service animal required because of a disability? and (2) What work or task has the dog been trained to perform? We will not ask for documentation, certification, or a demonstration of the animal's training.

7.3 Clinical Accommodations

We provide clinical accommodations for patients with disabilities to ensure equitable access to care. This includes accessible examination tables and equipment for patients with mobility limitations; appointment scheduling practices that allow adequate time for patients who need additional time; clinical staff training on effective communication with patients who have cognitive, psychiatric, or sensory disabilities; and modified procedure protocols where necessary to accommodate patients with specific disabilities. Please inform your care team of any accommodations you need at or before the time of your appointment.

8. Religious Organization Exemptions and Faith-Based Mission

8.1 Our Status as a Faith-Based Organization

Helix BioMedical is a 508(c)(1)(a) faith-based healthcare organization. As such, we retain certain protections under federal law for activities that are directly connected to our religious mission and identity. The Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb et seq., prohibits the federal government from substantially burdening the exercise of our sincere religious beliefs except to further a compelling governmental interest through the least restrictive means available.

8.2 Scope of Religious Exemptions

Where applicable law provides an exemption for religious organizations from specific non-discrimination requirements, and where we determine in good faith that compliance with such requirements would substantially burden our sincere religious beliefs, we may assert and exercise those exemptions in accordance with applicable law. Any such assertion will be narrowly tailored and applied only to the extent required to protect our sincere religious mission. We will always clearly communicate to individuals if a particular service is not available through our organization, and we will provide referrals to other providers who offer the requested service.

8.3 Scope of Clinical Non-Discrimination

Regardless of any faith-based exemptions we may assert with respect to specific services, we commit to providing emergency stabilizing care to all individuals without discrimination, to treating all patients with dignity and respect, and to providing non-judgmental referrals to other providers for any services we do not offer. We do not refuse to provide any service solely on the basis of a patient's identity; where we decline to provide a service, it is based on the nature of the service, not the identity of the patient.

9. Genetic Information (GINA)

The Genetic Information Nondiscrimination Act of 2008 (GINA), 42 U.S.C. 2000ff et seq., prohibits discrimination in health insurance and employment based on genetic information. As a healthcare provider, we comply with the HIPAA Genetic Information provisions (45 CFR Part 164) that expand GINA's non-discrimination protections to health plan issuers.

We will not use or disclose genetic information for underwriting purposes. We will not request or require genetic testing of patients as a condition of receiving services (except where genetic testing is clinically indicated and ordered by a treating clinician). We will not use an individual's genetic information, including information about an individual's predisposition to disease, to make decisions about the provision of clinical services.

We recognize that genetic information is particularly sensitive because it can affect not just the tested individual, but biological relatives who have not consented to testing. We apply heightened privacy protections to all genetic information in our custody, and we obtain separate specific informed consent before conducting any genetic test or using genetic information for research purposes.

10. Internal Grievance Procedure

10.1 Who May File

Any individual who believes they have been subjected to discrimination by Helix BioMedical, or who believes that Helix BioMedical has failed to provide required accommodations or language access services, may file an internal grievance. Grievances may be filed by the affected individual, by a personal representative, or by any individual who witnessed discriminatory treatment.

10.2 How to File

Grievances must be submitted in writing (by email, mail, or in person) to our Civil Rights Coordinator within 60 days of the alleged discriminatory act. A grievance form is available at our facilities and on our website. Alternatively, you may submit a written statement that includes: your name, address, and contact information; the name(s) of any individual(s) involved; the date, time, and location of the alleged discriminatory act; a description of the alleged discrimination; and any supporting documentation you wish to provide. Assistance filing a grievance is available upon request in any language we serve and in accessible formats for individuals with disabilities.

Civil Rights Coordinator contact: [email protected] | (702) 825-0288 | TTY: 711

10.3 Investigation and Response

Upon receiving a grievance, we will: acknowledge receipt of the grievance in writing within 5 business days; designate a trained investigator who is not a party to the grievance; conduct a prompt, thorough, and impartial investigation, including interviews with relevant parties and review of all available evidence; provide you with an opportunity to present your account and submit evidence; issue a written determination of the outcome of the investigation within 30 days of the date the grievance was received (or within 60 days for complex matters, with notice to you of the extension); and, where a violation is found, implement appropriate corrective action and follow-up measures.

10.4 Appeal Process

If you are dissatisfied with the outcome of the grievance investigation, you may appeal in writing within 15 days of receiving the determination. Your appeal will be reviewed by a different individual than the original investigator. We will issue a final determination on your appeal within 30 days. Filing a grievance or an appeal with us does not waive your right to file a complaint with a federal or state civil rights enforcement agency.

11. Filing Complaints with Federal Agencies

11.1 HHS Office for Civil Rights

You may file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights (OCR), regarding alleged violations of Section 1557 of the ACA, Title VI, Section 504, or the Age Discrimination Act. Complaints must generally be filed within 180 days of the date you knew or should have known of the alleged discrimination. OCR may extend this deadline for good cause shown. You may file a complaint online, by mail, or by phone:

• Online: ocrportal.hhs.gov/ocr/portal/lobby.jsf
• Mail: U.S. Department of Health and Human Services, Office for Civil Rights, 200 Independence Avenue, S.W., Room 509F, HHH Building, Washington, D.C. 20201
• Phone: 1-800-368-1019 | TDD: 1-800-537-7697
• Website: www.hhs.gov/ocr/complaints/index.html

11.2 Department of Justice

Complaints regarding violations of Title II of the Americans with Disabilities Act may also be filed with the U.S. Department of Justice, Civil Rights Division, Disability Rights Section, at www.ada.gov or 1-800-514-0301 (voice) | 1-800-514-0383 (TTY).

11.3 No Retaliation

We strictly prohibit retaliation against any individual for filing a discrimination complaint, participating in an investigation, or otherwise opposing discriminatory practices. Any employee, contractor, or volunteer who engages in retaliation is subject to discipline up to and including termination. Any patient or program participant who experiences retaliation should immediately report it to our Civil Rights Coordinator or directly to the applicable federal agency.

12. Contact Information

For questions about this Non-Discrimination Policy, to request language assistance or disability accommodations, or to file an internal grievance, please contact:

• Email: [email protected]
• Phone: (702) 825-0288
• TTY: 711
• Organization: Helix BioMedical, a 508(c)(1)(a) faith-based healthcare organization, Wyoming jurisdiction