In part three of our three-part educational series on Section 1557, the non-discrimination provision of the Affordable Care Act (ACA), we dive deeper into the practical steps healthcare organizations need to take to build a more inclusive and compliant system. This session focuses on effective communication strategies, grievance procedures, and policies to support individuals with disabilities.

This blog will provide an overview of the topics discussed in the final session and offer actionable insights to help you meet the requirements of Section 1557. If you missed the other topics covered in our series, check out [Part 1] and [Part 2] for a comprehensive understanding of the regulation. 

What is Section 1557?

Section 1557 is the non-discrimination provision of the Affordable Care Act (ACA), prohibiting discrimination on the grounds of race, color, national origin, sex, age, or disability in health programs or activities funded by the U.S. Department of Health and Human Services (HHS). It requires healthcare providers and organizations to take actionable steps to ensure equity in communication, access, and treatment.

This regulation mandates written policies, effective training, and thoughtful measures to accommodate patients with limited English proficiency (LEP), disabilities, or other barriers to equitable care.

See Also

Section 1557 in Action: Operational Best Practices

Benefits of Proactively Achieving Compliance

While compliance may appear challenging at first, aligning your organization with Section 1557 offers invaluable benefits:

• Enhanced Patient Care: Clear communication and access help patients feel supported and understood during their healthcare experiences.
• Legal Safeguards: Proper policies, grievance procedures, and training reduce your organization’s vulnerability to fines and legal action.
• Reputation Building: Demonstrating inclusivity and proactive compliance strengthens patient trust and reinforces your organization as a leader in ethical healthcare practices.

Core Focus Areas of Section 1557 Compliance, Part 3

1. Written Grievance Procedure

Comprehensive, written policies are the backbone of Section 1557 compliance. 

Key Requirements:

• Grievance Process: In the required written policy, include detailed procedures for filing, resolving, and appealing grievances. Ensure timelines for response are reasonably quick (e.g., 30 days) and that documentation is retained for at least three years.
• Transparency: Patients need to know how to report issues. Distribute and visibly display notices of non-discrimination.
• Adjustable Templates: Utilize this sample template  for grievance procedures and modify them to fit your organization’s specific needs and scale.

2. Staff Training

It is valuable to train your workforce to understand and respond to the requirements of Section 1557. Training builds awareness, reduces the risk of non-compliance, and equips employees to make smart decisions in real-world scenarios.

Training Recommendations:

• Who to Train: Identify “relevant employees,” which includes anyone who interacts directly with patients or makes decisions affecting care (e.g., physicians, nurses, front desk staff, billing professionals, executive leadership).
• Frequency: Provide initial training for all staff, with refresher courses at least annually. Include training for new hires within 30 days of their start date.
• Content:

1. Nondiscrimination Policy

2. Grievance Procedures

3. Language Access Procedures

4. Effective Communication Procedures (for individuals with disabilities)

5. Reasonable Modification Procedures – this includes how a hospital adjusts policies and practices to accommodate individuals, such as how to request an interpreter or access to auxiliary aids.

Hospitals must also maintain records of the training they provide.

3. Monitoring and Documentation

Without proper monitoring and documentation, even well-intentioned compliance efforts can fall short. Section 1557 requires healthcare organizations to maintain updated records of their compliance activities, including:

• Training attendance logs
• Grievance reports and resolution timelines
• Detailed lists of available translated documents and auxiliary aids

By maintaining thorough records, you will be prepared for audits and demonstrate accountability to your patients and stakeholders.

Common Pitfalls and How to Avoid Them

1. Assuming English Proficiency Equals Health Literacy

Even patients who speak English fluently may struggle to understand complex medical terminology. Always assess the adequacy of your communication tools for every patient interaction.

2. Forgetting Non-Obvious Disability Accommodations

Disabilities extend beyond visual and hearing impairments. Consider accommodations for patients with cognitive disabilities, autism spectrum disorders, or mobility challenges.

3. Treating Compliance as a "One and Done" Task

Compliance should not be a checklist item. Make it an ongoing effort by conducting regular audits, refreshing policies, and seeking feedback from patients and staff.

Turning Compliance into Competitive Advantage

Achieving compliance with Section 1557 is more than just fulfilling a legal obligation. It can be a differentiating factor for your organization, setting you apart as a leader in patient care and equity.

If you’re ready to make Section 1557 compliance an integral part of your organization’s success, AMN Healthcare is here to help. From policy creation to staff training and language access services, we provide tailored solutions that turn complexity into clarity. Contact us today to learn how we can help you better serve your patient population.

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