Section 1557 Grievance Procedure

1. Purpose

This procedure implements Section 1557 of the Affordable Care Act (42 U.S.C. § 18116) and its implementing regulations (45 CFR Part 92), which prohibit discrimination on the basis of race, color, national origin (including limited English proficiency), sex (including sexual orientation, gender identity, sex characteristics, and pregnancy or related conditions), age, or disability in health programs and activities that receive federal financial assistance. MNHC also complies with Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, Title II of the Americans with Disabilities Act, the Age Discrimination Act of 1975, and the California Unruh Civil Rights Act.

2. Who may file a grievance

Any person who believes that MNHC has discriminated against them (or against another person) in any health program or activity may file a grievance. This includes patients, family members, staff members, applicants, and any other member of the public. A person may also file a grievance on someone else's behalf with their written consent.

3. Section 1557 Coordinator

Grievances are filed with MNHC's Section 1557 Coordinator, who also serves as Compliance and Privacy Officer.

4. How to file

Grievances may be filed in writing, orally, or in any accessible format that is easiest for you (including large print, braille, audio, or with an interpreter). MNHC will provide a paper grievance form on request at no cost and will help you complete it if you wish.

Information that helps the investigator:

• Your name and how we can reach you (if you want a response)
• The name of the person affected (if different)
• What happened, when, and where
• The people involved (staff members, other patients)
• Why you believe the treatment was discriminatory
• Any supporting documents, photos, or witnesses

Anonymous grievances are accepted, but the lack of contact information may limit our ability to investigate and respond.

5. Timelines

1. Acknowledgement: within 5 business days of receipt, we will send you a written acknowledgement that we received your grievance, along with the next steps.
2. Investigation: the Section 1557 Coordinator (or a designated impartial investigator if the Coordinator has a conflict) will review the grievance, interview relevant parties, and review relevant records.
3. Written decision: within 30 calendar days of receipt of the grievance (with written extensions if complexity requires, up to a maximum of 60 calendar days), we will send you a written decision that includes findings of fact, conclusions, and any corrective action.
4. Appeal: if you are dissatisfied with the decision, you may appeal to MNHC's Chief Executive Officer within 15 business days. The appeal must be submitted in writing (or in an accessible alternative format) and include the reasons the initial decision was wrong. The CEO will issue a final written decision within 30 calendar days.

6. No retaliation

MNHC will not retaliate against you or any person for filing a grievance, cooperating with an investigation, or opposing a practice you believe is discriminatory. Retaliation itself is a violation of Section 1557 and may be reported through this same procedure or directly to HHS OCR.

7. Confidentiality

MNHC will keep your grievance as confidential as possible, sharing information only with those who need to know in order to investigate and resolve the matter. Your ongoing medical care will never be affected by filing a grievance. Protected health information (PHI) shared in a grievance remains protected under HIPAA and California's Confidentiality of Medical Information Act.

8. Free help filing

If you need language assistance (interpreter, document translation, alternative format) to file or follow a grievance, MNHC will provide it at no cost. Call (415) 552-3870 and see our Notice of Availability of Language Assistance for details.

9. Alternative procedures

Filing a grievance with MNHC is not a prerequisite to filing a complaint with a government agency. You may file a complaint directly with:

• U.S. Department of Health & Human Services, Office for Civil Rights — online at ocrportal.hhs.gov or by phone at 1-800-368-1019 (TDD 1-800-537-7697).
• California Civil Rights Department — online at calcivilrights.ca.gov (formerly DFEH).
• California Attorney General's Office — for matters related to medical confidentiality under CMIA, oag.ca.gov.

Website-accessibility-related grievances may also be filed through the channels described in our Accessibility Statement.

10. Recordkeeping

MNHC maintains records of all Section 1557 grievances, investigations, and resolutions for at least three (3) years, as required by 45 CFR §92.7(c). These records are confidential and are used for pattern identification, staff training, and compliance.