Golden Frog Home Care and Adult Day Care Nondiscrimination Policy

NON-DISCRIMINATION, CIVIL RIGHTS, EQUAL ACCESS, AND EQUAL EMPLOYMENT OPPORTUNITY POLICY

Effective Date: 08/20/2026
Last Reviewed: 08/20/2026
Policy Owner: Golden Frog Home Care and Adult Day Care
Contact: goldenfrogcare@gmail.com| 720-726-3803

1. PURPOSE

Golden Frog Home Care and Adult Day Care is committed to providing a safe, respectful, inclusive, and discrimination-free environment for every person who receives our services, works for our organization, applies for employment, or otherwise participates in our programs and activities.

We respect the dignity, rights, privacy, individuality, cultural preferences, choices, and independence of each person.

Golden Frog Home Care and Adult Day Care complies with applicable federal, Colorado, and local civil-rights and employment laws and requirements applicable to our programs and operations.

For Health First Colorado/Medicaid services, applicable civil-rights requirements include protections related to race, color, national origin, ancestry, age, sex, religion, disability, sexual orientation, gender identity/expression, and other protected characteristics under applicable law. Colorado HCPF's provider guidance specifically requires providers to comply with applicable civil-rights and anti-discrimination laws. 

2. WHO THIS POLICY PROTECTS

This policy applies to and protects:

• Current  and prospective clients; 
• Adult Day Care participants; 
• Clients' representatives and family members; 
• Employees;      
• Job applicants; 
• Caregivers;      
• Supervisors and managers; 
• Volunteers;      
• Contractors and other persons acting on behalf of Golden Frog Home Care and Adult Day Care; 
• Visitors and other individuals participating in agency programs or activities. 

3. NON-DISCRIMINATION

Golden Frog Home Care and Adult Day Care does not discriminate against, exclude, deny benefits or services to, or otherwise treat an individual differently on the basis of any characteristic protected by applicable law.

Protected characteristics may include, as applicable:

• Race; 
• Color;      
• Ethnicity;      
• National origin; 
• Ancestry;      
• Age; 
• Sex; 
• Pregnancy, childbirth, or related conditions; 
• Sexual orientation; 
• Gender identity or expression; 
• Religion or creed; 
• Disability;      
• Marital status; 
• Veteran status; 
• Genetic information; 
• Political beliefs, where protected by applicable program requirements; 
• Any other characteristic protected by federal, Colorado, or local law. 

The list above is not intended to limit any protection provided by applicable law.

4. CLIENTS AND ADULT DAY CARE PARTICIPANTS

Golden Frog Home Care and Adult Day Care provides services based on:

• Individual needs; 
• Authorized services; 
• Program eligibility; 
• Individual service plans; 
• Client preferences; 
• Safety requirements; 
• Applicable laws and regulations. 

Clients and Adult Day Care participants have the right to receive services in an environment that promotes:

• Dignity;      
• Respect;      
• Privacy;      
• Independence;      
• Choice;      
• Self-determination;      
• Safety;      
• Cultural sensitivity; 
• Freedom from discrimination, abuse, neglect, exploitation, harassment, and retaliation. 

A person's protected characteristic will not be used as a reason to deny or limit services when the person otherwise qualifies for those services.

5. PERSON-CENTERED AND CULTURALLY RESPONSIVE SERVICES

Golden Frog Home Care and Adult Day Care recognizes that each person is unique.

Staff are expected to respect reasonable individual preferences related to:

• Culture;      
• Language;      
• Communication;      
• Religion;      
• Food and dietary preferences; 
• Family relationships; 
• Daily routines; 
• Personal preferences; 
• Gender-related preferences; 
• Disability-related needs. 

Employees must not impose their personal beliefs, cultural practices, religious beliefs, or personal preferences on clients.

Services should be provided in a respectful and person-centered manner consistent with the client's authorized services, individual needs, safety, and applicable requirements.

6. ACCESS FOR INDIVIDUALS WITH DISABILITIES

Golden Frog Home Care and Adult Day Care is committed to providing individuals with disabilities an equal opportunity to participate in and benefit from our services, programs, activities, and employment opportunities.

When required by applicable law, we will provide reasonable accommodations and reasonable modifications to policies, practices, procedures, or services when necessary to provide equal access.

Examples may include, when appropriate:

• Accessible communication; 
• Assistance with mobility; 
• Reasonable changes to procedures; 
• Auxiliary aids and services; 
• Accessible formats; 
• Qualified interpreters; 
• Other appropriate accommodations. 

Reasonable modifications are subject to applicable legal requirements and may be limited when a requested modification would fundamentally alter the nature of the service or program or create an undue burden, as applicable. Colorado HCPF uses the same framework for reasonable modifications under its disability-rights procedures. 

7. EFFECTIVE COMMUNICATION

Golden Frog Home Care and Adult Day Care will take appropriate steps to provide effective communication to individuals with disabilities.

This may include individuals who are:

• Deaf or hard of hearing; 
• Blind or have low vision; 
• Have speech disabilities; 
• Have other communication disabilities. 

When necessary for effective communication, appropriate auxiliary aids and services may include qualified interpreters, accessible written materials, large-print materials, or other appropriate methods.

When required, these services will be provided in a timely manner and without cost to the individual. HHS guidance specifically addresses the obligation of covered health programs to provide effective communication and appropriate auxiliary aids and services for individuals with disabilities. 

8. LANGUAGE ACCESS

Golden Frog Home Care and Adult Day Care recognizes that some clients and families have Limited English Proficiency (LEP).

We will take reasonable steps to provide meaningful access to services and important information for individuals whose primary language is not English, consistent with applicable federal and Colorado requirements.

Language assistance may include:

• Qualified oral interpretation; 
• Telephone or video interpretation; 
• Appropriate translated materials; 
• Bilingual staff when appropriately qualified; 
• Other appropriate language-assistance methods. 

When interpretation is necessary, the agency will use appropriate and qualified language assistance rather than relying on children or untrained individuals to interpret important service or health information whenever practicable and required. HHS and Colorado HCPF guidance emphasize meaningful language access and appropriate interpretation services. 

Language assistance will be provided without discrimination or retaliation.

9. EQUAL EMPLOYMENT OPPORTUNITY

Golden Frog Home Care and Adult Day Care is an Equal Employment Opportunity employer.

Employment decisions are based on legitimate job-related qualifications, experience, performance, business needs, and applicable requirements—not on unlawful discrimination.

This policy applies to:

• Recruitment;      
• Job advertisements; 
• Applications;      
• Interviews;      
• Hiring;      
• Orientation;      
• Training;      
• Scheduling;      
• Compensation;      
• Promotion;      
• Job assignments; 
• Performance evaluations; 
• Discipline;      
• Benefits;      
• Transfers;      
• Termination;      
• Other employment-related decisions. 

Employees and applicants will be provided reasonable accommodations when required by applicable law.

10. WORKPLACE HARASSMENT

Golden Frog Home Care and Adult Day Care does not tolerate unlawful harassment or discriminatory conduct involving employees, clients, families, applicants, contractors, or other individuals.

Prohibited conduct may include inappropriate verbal, physical, visual, written, electronic, or other conduct based on a protected characteristic.

Examples may include:

• Discriminatory insults or slurs; 
• Threats or intimidation; 
• Offensive jokes; 
• Unwanted sexual conduct; 
• Repeated discriminatory comments; 
• Deliberate exclusion based on a protected characteristic; 
• Other conduct prohibited by applicable law. 

Employees are expected to maintain professional behavior at all times.

11. RELIGIOUS AND CULTURAL ACCOMMODATION

Golden Frog Home Care and Adult Day Care will consider reasonable requests related to sincerely held religious practices and cultural needs when required by applicable law.

Employees should communicate accommodation requests to management as soon as reasonably possible.

Clients should communicate service preferences or accommodation needs to the agency so that the agency can evaluate and address the request appropriately.

12. SERVICE ANIMALS AND ACCESSIBILITY

Golden Frog Home Care and Adult Day Care will comply with applicable disability-access requirements concerning service animals and assistive devices.

Clients will not be denied appropriate access to services solely because they use a disability-related assistive device or service animal when applicable law protects that access.

13. COMPLAINTS AND GRIEVANCES

Any client, family member, employee, applicant, or other individual who believes they have experienced discrimination is encouraged to report the concern.

Complaints may be submitted by:

Email: goldenfrogcare@gmail.com
Phone: 720-726-3803

Individuals may request assistance in making a complaint or communicating their concern.

Golden Frog Home Care and Adult Day Care will:

1. Receive the complaint respectfully; 
2. Document the complaint; 
3. Review the concern; 
4. Conduct an appropriate investigation when necessary; 
5. Take appropriate corrective action when warranted; 
6. Maintain confidentiality to the extent reasonably possible; 
7. Follow applicable reporting requirements. 

Civil-rights complaints involving Health First Colorado/Medicaid may also be directed to the appropriate Colorado HCPF or federal civil-rights authority. HCPF provides a civil-rights complaint process and contact information for its 504/ADA Coordinator and the U.S. Department of Health and Human Services Office for Civil Rights. 

14. NO RETALIATION

Golden Frog Home Care and Adult Day Care strictly prohibits retaliation against any person who, in good faith:

• Reports discrimination; 
• Reports harassment; 
• Files a grievance or complaint; 
• Requests an accommodation; 
• Requests language assistance; 
• Reports a civil-rights concern; 
• Participates in an investigation; 
• Exercises a legal right. 

Retaliation may result in corrective or disciplinary action, up to and including termination of employment when appropriate.

15. CONFIDENTIALITY

Complaints and related information will be handled as confidentially as reasonably possible and will be shared only with individuals who have a legitimate need to know, consistent with applicable law and agency policy.

Client health information and other protected information will be handled according to applicable privacy and confidentiality requirements.

16. EMPLOYEE RESPONSIBILITIES

All Golden Frog Home Care and Adult Day Care employees are responsible for:

• Treating clients and coworkers with dignity and respect; 
• Following this policy; 
• Avoiding discriminatory behavior; 
• Maintaining professional boundaries; 
• Respecting cultural and individual preferences; 
• Providing services without discrimination; 
• Reporting suspected discrimination or harassment; 
• Cooperating with investigations; 
• Protecting confidential information; 
• Completing required civil-rights and nondiscrimination training. 

Supervisors and managers have additional responsibility to promptly address complaints and escalate concerns according to agency policy.

17. MANAGEMENT RESPONSIBILITIES

Golden Frog Home Care and Adult Day Care management will:

• Maintain this policy; 
• Communicate      the policy to employees and clients; 
• Provide appropriate staff training; 
• Maintain procedures for discrimination complaints; 
• Review complaints promptly; 
• Take corrective action when appropriate; 
• Monitor compliance; 
• Maintain required documentation; 
• Review the policy periodically and update it when applicable laws or program      requirements change. 

HCPF materials emphasize the importance of having procedures for discrimination grievances, identifying the person responsible for investigating complaints, assisting individuals who need help filing complaints, tracking complaints, and training staff. 

18. COMPLIANCE WITH CIVIL RIGHTS LAWS

Golden Frog Home Care and Adult Day Care will comply with applicable requirements, including, as applicable:

• Title VI of the Civil Rights Act of 1964; 
• Section  504 of the Rehabilitation Act of 1973; 
• Americans with Disabilities Act (ADA); 
• Age Discrimination Act of 1975; 
• Section 1557 of the Affordable Care Act; 
• Applicable Colorado civil-rights and anti-discrimination laws; 
• Applicable Medicaid/Health First Colorado requirements; 
• Other applicable federal, state, and local requirements. 

HCPF identifies Title VI, Section 504, ADA, Age Discrimination Act, and Section 1557 among the civil-rights authorities applicable to its programs and services. 

Important: Federal Section 1557 requirements and litigation affecting portions of the 2024 rule can change. Therefore, Golden Frog should periodically review its civil-rights notice and procedures rather than treating this webpage as a permanent substitute for regulatory review. HHS currently notes that certain provisions of the 2024 Section 1557 rule are subject to stays or injunctions. 

19. CONTACT GOLDEN FROG HOME CARE AND ADULT DAY CARE

If you have questions, need an accommodation, need language assistance, or wish to report discrimination or harassment:

Golden Frog Home Care and Adult Day Care
Email: goldenfrogcare@gmail.com
Phone: 720-726-3803

We are committed to responding to concerns promptly, respectfully, and fairly.

GOLDEN FROG COMMITMENT

Every client deserves dignity.
Every employee deserves respect.
Every individual deserves equal access and equal opportunity.

Golden Frog Home Care and Adult Day Care is committed to maintaining an environment where people can receive services, work, participate, and communicate free from unlawful discrimination, harassment, and retaliation.