TLCS, Inc OPERATING PROCEDURES MANUAL
SUBJECT: Equal Access Policy and Procedure Standards SECTION: FORM: EFFECTIVE DATE: December 2016
I. PURPOSE TLCS is committed to comply with all laws regarding HUD’s Equal Access Rule and is committed to comply with federal, state and local privacy laws. This policy outlines policy and procedure standards to which TLCS will adhere in relation to the HUD Equal Access Rule.
II. USERS All TLCS housing program staff, volunteers, interns and vendors.
III. PROCEDURE
A. TLCS will use appropriate, inclusive language in communications, publications, trainings, personnel handbooks and other policy documents that affirms the agency’s commitment to serving all eligible clients in adherence with the HUD Equal Access Rule.
B. TLCS will continue to develop partnerships with organizations that can provide expertise around the process of changing gender markers on identification and benefit applications or will ensures subject matter expertise among staff.
C. TLCS will be alert to and correct any misinformation or inaccurate conclusions that transgender clients threaten the health or safety of other clients solely based on their non-conforming gender identity/expression during risk-based conversations.
D. TLCS will keep a client's transgender status confidential, unless the client gives permission to share this information.
E. TLCS will ensure that only essential staff, identified by administrators, are told about a client’s transgender status to ensure equal access and safety.
F. TLCS will ensure that when a client's gender identity and sex assigned at birth differ, that difference is treated as confidential medical information and may not be disclosed without specific, time-limited written client consent. Similarly a client’s legal name will be treated as confidential information.
G. TLCS supports all clients in understanding their privacy rights and the implication of releasing information.
H. TLCS will ensure staff, volunteers and contractors maintain the confidentiality of a client’s legal name and gender at birth and understands the potential impact that disclosure can have on a client's progress to self-sufficiency.
I. TLCS will ensure that staff, volunteers and contractors understand that a client may not present as the way they identify. Staff, volunteers and contractors will respect the client’s preferred identity.
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J. TLCS will respect the client's evaluation of their own safety with regard to proposed housing options and accommodate reasonable client requests regarding safety. Staff, volunteers and contractors will reasonably defer to client's request and recommend accommodations with safety concerns in mind.
K. When possible, TLCS will ensure that construction or property rehabilitation includes and promotes privacy and safety in sleeping area, bathrooms, and showers.
L. TLCS will have a single check-in area for both genders, as applicable.
M. If a TLCS Program only offers congregate bathrooms or showers, all urinals/toilets and shower heads will have individual stalls to support client safety.
N. TLCS will offer individual gender-neutral bathrooms and gender-neutral shower rooms, where feasible.
O. TLCS will mediate and resolve conflicts between clients in a way that is respectful, fair and equitable.
P. TLCS Equal Access Rule Policies and Procedures will be publicly available on the agency's website and through other commonly used public notification processes.
Q. TLCS will take immediate action to resolve inappropriate behavior, harassment, or equal access issues by any person (staff, volunteers, contractors or clients).
R. Staff training regarding inappropriate behavior, harassment, or equal access issues will include role play on interventions (staff to staff, staff to resident, and resident to resident).
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IV. DISPOSITION
Written By: Approved By:
Date: Date:
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