What is the COA360?

The COA360° is designed to assess the "cultural competency" of healthcare organizations, rather than individuals. It is a multi-dimensional tool which provides a "360-degree view" of organizational units from the perspective of healthcare administrators, providers, non-provider staff, and clients/patients. The measure was designed for use in hospital organizational "sub-units," such as clinical departments, hospital inpatient service units, or outpatient units and is adaptable to the unique configuration of diversity within an organization’s service area (i.e. nationality, ethnicity, language, tribal affiliation or religion). Additionally, there is an optional questionnaire for persons living in the service area who have not been clients/patients of the healthcare organization.

The COA360° is administered via the world-wide-web, which facilitates its ease of access and use. Currently, the tool is available only in English; however, we intend to make it available in other languages in the future.

The assessment tool uses a combination of subjective and statistical data to produce scores for each of the 14 COA360° domains based on the 14-item CLAS standards established by the United States Department of Health and Human Services, Office of Minority Health (2001). The result of this web-based tool is a 360-degree assessment similar to 360-degree assessments regularly used in leadership/management and organizational assessments. The report provides feedback for each of the 14 CLAS standards based on a set of questions developed to measure each standard, as well as the relevant Joint Commission standards. The number of COA360° items per CLAS Standard ranges from three to nine (see Table 2). Also, the Joint Commission produced an extensive guide linking the CLAS Standards to relevant existing Joint Commission accreditation standards. The COA360° can also be linked to the cultural competency domains identified by the Joint Commission (See Table 1 below).

Table 1. Joint Commission accreditation domains related to cultural competency

Joint Commission Doman	# of COA360 Items Measuring Domain
Leadership	22
Workforce	34
Quality Improvement and Data Use	40
Patient Safety	28
Language Services	7
Community Engagement	13

Table 2. Culturally and Linguistically Appropriate Services (CLAS) Standards

CLAS Standard	# of COA360 Items Measuring Standard
Standard 1: Health care organizations should ensure that patients/consumers receive from all staff member's effective, understandable, and respectful care that is provided in a manner compatible with their cultural health beliefs and practices and preferred language.	9
Standard 2: Health care organizations should implement strategies to recruit, retain, and promote at all levels of the organization a diverse staff and leadership that are representative of the demographic characteristics of the service area.	6
Standard 3: Health care organizations should ensure that staff at all levels and across all disciplines receive ongoing education and training in culturally and linguistically appropriate service delivery.	7
Standard 4: Health care organizations must offer and provide language assistance services, including bilingual staff and interpreter services, at no cost to each patient/consumer with limited English proficiency at all points of contact, in a timely manner during all hours of operation.	9
Standard 5: Health care organizations must provide to patients/consumers in their preferred language both verbal offers and written notices informing them of their right to receive language assistance services.	3
Standard 6: Health care organizations must assure the competence of language assistance provided to limited English proficient patients/consumers by interpreters and bilingual staff. Family and friends should not be used to provide interpretation services (except on request by the patient/consumer).	8
Standard 7: Health care organizations must make available easily understood patient-related materials and post signage in the languages of the commonly encountered groups and/or groups represented in the service area.	4
Standard 8: Health care organizations should develop, implement, and promote a written strategic plan that outlines clear goals, policies, operational plans, and management accountability/oversight mechanisms to provide culturally and linguistically appropriate services.	3
Standard 9: Health care organizations should conduct initial and ongoing organizational self-assessments of CLAS-related activities and are encouraged to integrate cultural and linguistic competence-related measures into their internal audits, performance improvement programs, patient satisfaction assessments, and outcomes-based evaluations.	4
Standard 10: Health care organizations should ensure that data on the individual patient's/consumer's race, ethnicity, and spoken and written language are collected in health records, integrated into the organization's management information systems, and periodically updated.	5
Standard 11: Health care organizations should maintain a current demographic, cultural, and epidemiological profile of the community as well as a needs assessment to accurately plan for and implement services that respond to the cultural and linguistic characteristics of the service area.	3
Standard 12: Health care organizations should develop participatory, collaborative partnerships with communities and utilize a variety of formal and informal mechanisms to facilitate community and patient/consumer involvement in designing and implementing CLAS-related activities.	6
Standard 13: Health care organizations should ensure that conflict and grievance resolution processes are culturally and linguistically sensitive and capable of identifying, preventing, and resolving cross-cultural conflicts or complaints by patients/consumers.	9
Standard 14: Health care organizations are encouraged to regularly make available to the public information about their progress and successful innovations in implementing the CLAS standards and to provide public notice in their communities about the availability of this information.	3

Source: U.S. DHHS, OPHS, OMH National Standards for Culturally and Linguistically Appropriate Services in Health Care, Final Report Washington, DC, March 2001

COA360° - Cultural Competency Organizational Assessment © 2010 The Johns Hopkins University