Auxiliary Aids and Communication Assistance

Last Revised: October 10, 2026

House of Freedom | Page 1HOUSE OF FREEDOM | AUXILIARY AIDS SERVICE & MONITORING PLAN

TABLE OF CONTENTS

01 | Policy, Purpose & Objectives

02 | Roles & Responsibilities

03 | Staff Training & Service Commitment

3.1 Staff Training Requirements

3.2 Staff Service Commitment

04 | Requests, Assessment & Providing Auxiliary Aids

4.1 When a Customer Requests Assistance

4.2 Request & Waiver Form

4.3 Assessing Communication Needs & Determining Essentiality

4.4 Aid Essential Situations

4.5 Non Aid Essential Situations

4.6 Refusal or Waiver

4.7 Records & Interpreter Verification

05 | Timelines & Effective Communication

5.1 Scheduled Appointments

5.2 Unscheduled Appointments

06 | Denials & Authorization

6.1 Requirements & Denial Authorization

07 | Interpreters, Privacy & Feedback

7.1 Interpreter Arrangements & Confidentiality

7.2 Family Members, Accompanying Adults & Minors

7.3 Customer Feedback

08 | Monitoring & Quality Assurance

8.1 Customer Record Monitoring

8.2 Employee Training Records

8.3 Retention & Equipment

8.4 Public Notices, Complaints & Corrective Action

APPENDIX A | Service & Referral Resource Directory

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01 Policy, Purpose & Objectives

It is the policy of HOUSE OF FREEDOM, INC. (HOF) to ensure that persons who are deaf or hard-of-

hearing are afforded equal opportunity in employment and in receiving services as stipulated by

Section 504 of the Rehabilitation Act of 1973 (hereinafter referred to as 'Section 504') and the

Americans with Disabilities Act (ADA), and Department of Children and Families Operating Policy

(DCF CFOP) 60-10, Chapters 1, 3 & 4.

The purpose of this plan is to ensure that all HOF staff working in a DCF contracted program comply

with Section 504 of Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA), and

Department of Children and Families Operating Policy (DCF CFOP) 60-10, Chapters 1, 3 & 4. This

plan delineates how HOF provides appropriate auxiliary aids and compliance with:

• Title II of the Americans with Disabilities Act (ADA);

• Section 504 of the Rehabilitation Act of 1973;

• Section M of the Settlement Agreement between the Department of Children and Families (DCF)

and the United States Department of Health and Human Services (HHS);

• DCF Operating Procedures; and

• HOF Auxiliary Aids Services Policies and Procedures.

Definition of Companion

A family member, friend, or associate of a customer who is an appropriate person for HOF to

communicate with regarding the customer's services, consistent with applicable privacy and

confidentiality requirements.

The goals and objectives of this plan are designed to identify methods within HOF's programs,

policies and procedures that ensure adequate provision of auxiliary aids and services to persons and

companions who are deaf or hard-of-hearing, have other disabilities, or have limited English

proficiency (LEP).

02 Roles & Responsibilities

HOF's Single Point of Contact (SPOC) is responsible for the development, implementation, revision

and oversight of this plan. Further, the SPOC's responsibility is to:

• Ensure effective communication with deaf or hard-of-hearing Customers or Companions in

accordance with the ADA and/or Section 504.

• Capture the information required in the Auxiliary Aid Service Record within each Customer's case

record.

• Summarize the records into a report and submit to the DCF Contract Manager who will forward to

the appropriate DCF ADA Section 504 Coordinator.

• Ensure that information is provided to any agency to which a deaf or hard-of-hearing Customer or

Companion is referred about the disabled person's requested auxiliary aid or service.

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• Coordinate revisions to the Auxiliary Aids Service & Monitoring Plan as necessary to reflect

changes in applicable requirements, organizational procedures, or available resources.

• Designate a Single-Point-of-Contact as each contractual agreement with DCF is renewed.

HOF staff are responsible for requesting and providing effective auxiliary aids and services based on

the customer's preference, on a 24/7 basis.

Requests are to be submitted to the SPOC in a timely manner: 7 days prior to scheduled

appointment date

03 Staff Training & Service Commitment

3.1 Staff Training Requirements

New Employee Orientation

• All new employees will attest in writing they are familiar with Section 504 and ADA Title II

requirements.

• The attestation form “Support to the Deaf and Hard-of-Hearing Attestation Form” will be

maintained in the employee's personnel file.

• Employees are initially trained on the requirements for the deaf or hard-of-hearing at orientation

when they are hired, but no later than 60 days from the commencement of employment.

Required Training & Documentation

• All employees will complete the Foundations of Disability Rights training.

• The designated SPOC will complete the Foundations of Disability Rights training and the

designated SPOC Deaf and Hard of Hearing training module through MyFLearn.

• Documentation of required training will be maintained in the employee’s personnel file.

Annual Refresher

• Refresher training on how to provide assistance to persons who are deaf or hard-of-hearing,

persons with disabilities and those who are limited English proficient is conducted on an annual

basis.

3.2 Staff Service Commitment

It is the responsibility of HOF staff to ensure that they will provide auxiliary aids and services, to

ensure effective communication with deaf or hard-of-hearing customers/companions.

Accommodations will be made within the scope of appropriate laws, agency policies and procedures

and the HOF Code of Ethics.

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04 Requests, Assessment & Providing Auxiliary Aids

4.1 When a Customer Requests Assistance

1. Immediately notify the Supervisor and Single-Point-of-Contact (SPOC).

2. Identify the requested auxiliary aid or service and the customer’s preferred communication

method. (Refer to Section 4.2: Request & Waiver Form)

3. Arrange access to the appropriate aid or service at no cost to the customer or companion.

4. Document the communication needs and services provided in the customer record.

4.2 Request & Waiver Form

Provide the customer with the Customer/Companion Request for Free Communication

Assistance or Waiver for Free Communication Assistance form.

• The form & instructions are located on the HOF Common drive - office share: O:\Clinical

Department\Aux Aids Forms

• The form is to be completed by the customer and not HOF staff member.

It must be completed in full with signatures if:

• A free interpreter is provided or;

• The customer waives a free interpreter

• This form must be completed each date of service and filed in client record.

• Upon completion of the form, HOF staff must immediately notify the Single Point of Contact

(SPOC) via email for monitoring and monthly DCF reporting purposes. The completed form must

remain in the customer's electronic health record (EHR) and must not be attached to the email.

The notification must not include protected health information (PHI). The SPOC will review the

form directly in the EHR as needed.

4.3 Assessing Communication Needs & Determining Essentiality

Determining essential vs. non-essential situations:

• The importance of the exchange

• The length of time the meeting will take

• The complexity of the information and of the situation

• The number of people involved

• Any health issues that may be affected by a technical device.

4.4 Aid Essential Situations

• Assessments, evaluations, and admissions.

• Treatment planning and treatment plan reviews.

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• Counseling or clinical interactions involving significant or complex information.

• Informed consent and explanation of client rights.

• Medication, medical, health, or safety related communication.

• Crisis or emergency situations.

• Discharge and transition planning.

• Grievances, disciplinary matters, or other significant decisions affecting the customer.

• Any other interaction where an alternative method would not provide equally effective

communication.

4.5 Non Aid Essential Situations

• Brief routine questions or exchanges.

• Basic directions.

• Scheduling or appointment information.

• Routine administrative communication.

• Other brief interactions where an alternative auxiliary aid or method provides equally effective

communication.

These examples are not automatically determinative. HOF staff will evaluate each situation

individually, considering the nature, length, complexity, and importance of the communication and

the customer or companion’s communication needs and preferred method of communication.

4.6 Refusal or Waiver

Customer/Companion Refusal or Waiver of Auxiliary Aids

If a customer or companion declines or waives an offered auxiliary aid or service, staff will document

the refusal or waiver on the applicable form. If the individual refuses to sign, staff will document

Refuses to Sign.

Staff will document the individual’s preferred method of communication and determine whether

effective communication can be achieved using that method or another appropriate method.

In an Aid Essential Situation, a refusal or waiver does not eliminate HOF’s responsibility to ensure

effective communication. Staff will reassess the communication needs and offer an appropriate

alternative auxiliary aid or service when necessary. If effective communication cannot be achieved,

staff will contact the SPOC or Supervisor.

In a Non-Aid Essential Situation, an alternative aid, service, or method may be used when it provides

equally effective communication. The method used and its effectiveness will be documented in the

client record.

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4.7 Records & Interpreter Verification

• Document the customer/companion’s preferred method of communication and any requested

auxiliary aids/services provided through the completion of the Customer/Companion

Communication Assessment and Auxiliary Aid Service Record form.

• The form & instructions are located on the HOF Common drive - office share: O:\Clinical

Department\Aux Aids Forms

• A list of certified language interpreters is available by accessing the HOF Common drive:

O:\Clinical Department\Aux Aids Forms

• Once completed, form must be filed in the customer's record.

• Upon completion of the form, HOF staff must immediately notify the Single Point of Contact

(SPOC) via email for monitoring and monthly DCF reporting purposes. The completed form must

remain in the customer's electronic health record (EHR) and must not be attached to the email.

The notification must not include protected health information (PHI). The SPOC will review the

form directly in the EHR as needed.

• The form must be completed or revised for each date of service or contact with the

customer/companion.

• A copy of state or national certification for any ASL interpreters will be obtained. Staff will verify

the interpreter's certification through the Registry of Interpreters for the Deaf (www.RID.org) or

by asking for a copy of the interpreter's certification card.

• HOF will use qualified interpreters who possess the appropriate certification or credentials

required for the interpreting service being provided.

• If an auxiliary aid or service is found to be ineffective, the HOF staff shall reassess to determine

an alternative form of communication that will be used in order to ensure the

customer/companion fully understands the information that is being provided.

05 Timelines & Effective Communication

5.1 Scheduled Appointments

Arranging Communication Assistance

HOF will arrange for a qualified interpreter or other appropriate auxiliary aid to be available at the

scheduled appointment time.

If the Interpreter Does Not Arrive

Staff will:

1. Immediately attempt to obtain a qualified replacement.

2. Arrange for the replacement as soon as possible, but no later than two (2) hours after the

scheduled appointment time, or coordinate an alternative appointment time convenient to the

customer or companion.

3. Document the circumstances, actions taken, and outcome in the customer record.

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5.2 Unscheduled Appointments

Initial Response

When a customer or companion arrives without an appointment and requires an interpreter or other

auxiliary aid, staff will:

1. Promptly assess the individual's communication needs.

2. Initiate arrangements for appropriate communication assistance.

3. Determine whether the situation is an emergency or non-emergency.

Emergency Situations

• Prioritize the individual's immediate safety and communication needs.

• Arrange for a qualified interpreter as soon as possible, but no later than two (2) hours from

the time the interpreter is requested.

• Do not delay necessary emergency assistance while arranging communication services.

Non-Emergency Situations

• Immediately attempt to arrange a qualified interpreter within two (2) hours.

• If an interpreter is unavailable, offer an appointment convenient to the customer or

companion, consistent with applicable DCF requirements.

• Notify the Supervisor or SPOC if difficulties arise in meeting the applicable timeframe.

Clinical Appointment Availability

The timelines for providing auxiliary aids do not independently guarantee the availability of a

counselor or other clinical professional.

• Schedule clinical appointments according to HOF's admission procedures, clinical urgency,

and available qualified personnel.

• Do not deny or delay services solely because an individual requires an auxiliary aid.

• If an appointment cannot be scheduled within the applicable timeframe, notify the

Supervisor or SPOC and arrange the earliest appropriate alternative.

Documentation

Staff will document the following in the customer record:

• The request for communication assistance.

• Arrangements made and any difficulties encountered.

• Interim communication assistance provided, when applicable.

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• Notifications to the Supervisor or SPOC.

• The final outcome, including any rescheduled appointment.

06 Denials & Authorization

6.1 Requirements & Denial Authorization

• In Aid-Essential Communication Situations, HOF will provide the requested auxiliary aid or

service. In Non-Aid Essential Communication Situations, an appropriate alternative may be

provided when it ensures equally effective communication.

• A denial of an auxiliary aid and service should only be done when it is a non-aid essential

communication situation.

• Staff must still ensure that effective communication is achieved through whatever alternative

means is provided.

If, after conducting the assessment, a particular auxiliary aid or service requested by a Customer

and/or Companion will not or cannot be provided, the staff member will document the reason/s the

Requested Auxiliary Aid or Service was not provided.

Only the SPOC, the Clinical Director, or the CEO can authorize the denial determination.

The person requesting the auxiliary aid or service shall be informed of the basis for the determination

or denial, including:

• The date of the determination

• The name and title of the staff member who made the determination

• The alternative auxiliary aid and service, if any, that HOF has decided to provide.

07 Interpreters, Privacy & Feedback

7.1 Interpreter Arrangements & Confidentiality

• Staff will ensure the Release of Confidential Information consent form is signed to allow

customer identifying information to be discussed in the presence of a certified sign language

interpreter and anyone else present.

• The form & instructions are located on the HOF Common drive - office share: O:\Clinical

Department\Aux Aids Forms

• House of Freedom will not require a customer or companion to provide his or her own interpreter.

• When an interpreter is necessary to ensure effective communication, House of Freedom will

provide an appropriate qualified interpreter or other auxiliary aid or service at no cost to the

customer or companion.

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7.2 Family Members, Accompanying Adults & Minors

• An accompanying adult may be used to interpret when specifically requested by the customer or

companion, the accompanying adult agrees to provide the assistance, and HOF determines

that using the individual is appropriate under the circumstances and will result in effective,

accurate, and impartial communication.

• HOF will not rely on an accompanying adult when there are concerns regarding effectiveness,

accuracy, impartiality, confidentiality, or a potential conflict of interest.

• A minor child will not be used as an interpreter except in an emergency involving an imminent

threat to the safety or welfare of an individual when a qualified interpreter is not available.

• In an emergency, an accompanying adult may provide temporary interpreting assistance when a

qualified interpreter is not available and there is an imminent threat to the safety or welfare of an

individual.

• HOF remains responsible for ensuring effective communication and for obtaining a qualified

interpreter or other appropriate auxiliary aid or service when necessary.

7.3 Customer Feedback

Staff is required by DCF to provide the Customer/Companion Feedback Form to the

customer/companion. Completion of the form is voluntary, and choosing not to complete the form

will not affect the customer or companion’s access to services or benefits. HOF will provide

assistance in understanding or completing the form, including interpreter services when necessary.

Staff should encourage participation but will respect the customer or companion’s decision whether

to complete the form.

The form & instructions are located on the HOF Common drive - office share: O:\Clinical

Department\Aux Aids Forms

Completed surveys are mailed to:

DCF, Office of Civil Rights

1317 Winewood Blvd. Bldg. 1, Rm 10

Tallahassee, FL 32399-0700

08 Monitoring & Quality Assurance

8.1 Customer Record Monitoring

The Single Point of Contact (SPOC) will conduct a review of randomly selected customer records

twice a year to monitor compliance with the procedures outlined in this plan. Records will be

selected from customers who received services during the preceding six months.

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During the review, the SPOC will verify that the following documentation is present in the

customer's record, when applicable:

• Customer/Companion Communication Assessment and Auxiliary Aid Service Record

• Customer/Companion Request for Free Communication Assistance or Waiver of Free

Communication Assistance

• Communication plan (if applicable, only when ongoing services are provided)

• Documentation confirming that the Customer/Companion Feedback Form was provided to the

customer or companion. The completed feedback form is mailed directly by the individual to

Tallahassee.

• Documentation of the auxiliary aid services provided

• Copy of the interpreter invoice, when applicable

Auxiliary aid services and related documentation will be documented in the Auxiliary Aid Services

form located under the Miscellaneous tab of the customer’s electronic health record (EHR).

8.2 Employee Training Records

Employee HR Records are reviewed by the HR assistant annually for compliance with required

documentation:

• Attestation of “Support to the Deaf and Hard-of-Hearing Form”

• Certificate of Auxiliary Aids training within 60 days of hire

• Auxiliary aids refresher training annually.

8.3 Retention & Equipment

Records and documentation relating to auxiliary aids and services provided will be retained for a

minimum of ten (10) years in accordance with CFCHS requirements. If any litigation, claim,

negotiation, audit, or other action involving these records begins before the expiration of the

retention period, the records will be retained until the action is completed and all related issues are

resolved.

Equipment will be inspected in order to determine the need for any maintenance on a bi-annual

basis, at the same time the quality assurance of records is conducted.

HOF will purchase auxiliary aid equipment upon receipt of its first request for a particular equipment.

At which time employees will be trained on the use of such equipment and will be provided with

refresher courses on a yearly basis.

8.4 Public Notices, Complaints & Corrective Action

• If HOF holds a public meeting, conference, or seminar the SPOC will review the

notice/documents advertising the events to the public in order to ensure that there is an

addendum stating: "Pursuant to the provisions to the Americans with Disabilities Act, any

person requiring special accommodations to participate in these meetings is asked to advise

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the agency at least 48 hours before the meeting by contacting the Single-Point- of-Contact

(SPOC) at 407-957-9077. If you are hearing or speech impaired, please contact the agency

using the Florida Relay Service, (800) 955-8771 (TTY) or (800) 955-8770 (Voice).

• A copy of the Auxiliary Aids Plan will be posted on the HOF website to be made available to the

public for informational purposes for both individuals and organizations. Printed documents

may be made available in alternate formats upon request to assist in ensuring effective

communication, and will depend upon the customer or companion's preferred method.

• If a customer/companion has a complaint regarding auxiliary aids, the staff member must inform

the customer/companion of his/her right to contact DCF Office of Civil Rights, U.S. Department

of Health and Human Services (HHS), and/ or the U.S. Department of Justice (USDOJ) – Contact

information is available in the client’s handbook.

• Any complaints or grievances received by the Supervisor of a department that are related to the

provision of auxiliary aids and services will be forwarded to the SPOC for review.

• If deficiencies are found in any area, corrective actions will be taken including, but are not limited

to, retraining staff, programmatic system review, or other actions as appropriate.

• Where necessary, policies and procedures will be revised to reflect current DCF policy relative to

providing auxiliary aids and services to persons or companions who are deaf or hard- of-hearing.

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APPENDIX A: Service & Referral Resource Directory

American Sign Language and Qualified Sign Language Interpreters

Interpretek (Orlando) 407-339-4835 orl.office@interpretek.com | interpretek.com

ASL Services, Inc. 407-518-7900 aslservices.com

Deaf Talk, LLC 321-352-7778 deaftalkllc.com

Florida Registry of Interpreters for

the Deaf (FRID)

Interpreter directory fridcentral.org/member-directory

Florida Relay and Telecommunications Resources

Florida Relay Service / Florida

Telecommunications Relay, Inc.

(FTRI)

Dial 7-1-1 ftri.org | ftri.org/florida-relay-711/

FTRI provides information about specialized telecommunications equipment and available assistance

programs.

Captioning in Real Time (CART)

Kaptions4U, LLC 352-516-8310 kaptions4u@gmail.com | ikaption4u.com

Alternative Communication

Services, LLC

800-335-0911 info@acscaptions.com | acscaptions.com

NCRA PROLink Professional

Auxiliary Aids and Communication Assistance

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