Affordable Care Act Section 1557 Notice of Proposed Rulemaking
DREDF submitted comments on proposed regulations issued under Section 1557 of the Affordable Care Act, on non-discrimination in federally funded and federally conducted healthcare activities and programs such as Medicaid, Medicare, and the federal and state marketplaces. (November 9, 2015)
DREDF responds to CMS request for information on new system for paying Medicare providers.
DREDF responds to the Center for Medicare and Medicare Services’ (CMS) requests Information regarding the Merit-based Incentive Program and Alternative Payment Model in the Medicare program (RFI). (November 17, 2015)
Federal Health IT Strategic Plan 2015 — 2020
We commented on the urgent need to track disability status, specific functional impairment, and reasonable accommodation or policy modifications needed as a first critical step needed to measure and understand the health disparities experienced by people with disabilities. (February 6, 2015)
Comments on Notice of Benefit and Payment Parameters for 2016
DREDF submitted comments on HHS proposed rules affecting implementation of portions of the Affordable Care Act that directly affect people with disabilities. In addition to supporting comments submitted by the Consortium for Citizens with Disabilities (CCD), we urged HHS to issue comprehensive language access standards and technical support for navigator and non-navigator assistance personnel to ensure that people with communication disabilities have equal access to the Health Insurance Marketplace. We also urged HHS to direct Navigator assistance organizations to comply with federal disability rights laws and regulations. (December 22, 2014)
Electronic Health Record (EHR) Certification
We call for full accessibility and that EHR should record functional impairments and accommodation needs of people with disabilities. (April 28, 2014)
Section 1557 of the Affordable Care Act
DREDF and colleagues submitted extensive comments to the US Department of Health and Human Services (HHS) Office for Civil Rights on proposed regulations implementing Section 1557 of the ACA, which prohibits discrimination in healthcare. Fifty-seven diverse, national disability rights, health policy, consumer advocacy, racial and ethnic health disparity, public health, and research organizations endorsed our comments. (September 30, 2013)
Proposed Single Streamlined Insurance Marketplace Application
We provided extensive comments and recommendations on the Center for Medicare and Medicaid Services proposed rule regarding Medicaid, Children’s Health Insurance Programs, and Exchanges: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes for Medicaid and Exchange Eligibility Appeals and Other Provisions Related to Eligibility and Enrollment for Exchanges, Medicaid and CHIP, and Medicaid Premiums and Cost Sharing. (February 28, 2013)
Joint Comments on Proposed Regulations for Wellness Programs in Group Plans (PDF)
DREDF joins other groups commenting on proposed Affordable Care Act regulations. The Consortium for Citizens with Disabilities (CCD) submitted comments to the US Department of Labor, Internal Revenue Service of the Treasury Department, and HHS/CMS that they are able to meet the unique service needs at each individual may have regardless of target group on proposed regulations concerning Incentives for Nondiscriminatory Wellness Programs in Group Health Plans. DREDF contributed to the letter and signed on as a member of CCD. (January 25, 2013)
Stage 3 Definition of Meaningful Use of Electronic Health Records
We urged the Office of the National Coordinator for Health Information technology of the US Department of Health and Human Services to adopt a number of recommendations including requiring eligible providers and hospitals to formalize, through established forms and procedures, the collection of information voluntarily obtained from patients, or with the assistance of their chosen authorized representatives, concerning their functional impairment status and accommodation needs, distinct from their medical diagnosis or condition(s). (January 14, 2013)
Proposed Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation under the Patient Protection and Affordable Care Act
In comments to the Centers for Medicare and Medicaid Services, we point out the absence of specific standards relating to when benefit design and implementation discriminates against individuals in terms of age, expected length of life, present or predicted disability, degree of medical dependency, quality of life, or other health conditions. We also call for firm guidance on how to make discrimination-free decisions on coverage, reimbursement rate determination, incentive programs, and other aspects of benefit design and implementation, in order to alleviate the uncertainty and potential for underinsurance faced by millions of PWD across the country. (December 26, 2012)
The State Option to Provide Home and Community—Based Services (HCBS) for Medicaid–Eligible Individuals
We call on the Centers for Medicare and Medicaid Services to finalize a rule that provides states and providers with strong and unequivocal guidance regarding the need to offer, develop, and provide chronic care services in the most integrated settings possible. (July 2, 2012)
The Access Board’s Proposed Accessibility Standards for Medical Diagnostic Equipment
DREDF and colleagues comment on the Access Board’s proposed accessibility standards for medical diagnostic equipment. (June 8, 2012)
Electronic Health Record Incentive Program—Stage 2
We comment on the inadequacy of rules proposed by the National Coordinator for Health Information Technology and the Office of the National Coordinator for Health Information Technology to improve health and healthcare equity for people with disabilities. (May 7, 2012)
Proposed ACA disability data collection standards
We strongly support the US Department of Health and Human Services proposal to use a standard set of questions on disability that span all federal surveys that gather demographic data. This is a significant step in strengthening the capacity for comparison between findings of different survey instruments. (August 1, 2011)
Home and Community—Based Services Waivers
We commented on the Center for Medicare and Medicaid Services proposed rule for Home and Community-Based Services Waivers, recommending that the requirements that “states must assure that
CMS that they are able to meet the unique service needs that each individual may have regardless of target group, and that each individual in the waiver has equal access to all needed services” and that waivers serving multiple target groups must cover an array of services specifically needed by each of the covered groups. (June 14, 2011)
Accountable Care Organizations
DREDF and colleagues wrote to the Centers for Medicare and Medicaid Serices to express our concern that healthcare policymakers and health care delivery systems alike have historically failed to recognize and acknowledge health care disparities and barriers to care that people with disabilities experience. This omission undermines the potential effectiveness of the ACO model. (June 6, 2011)
Health Disparity Research and Data Collection
We drafted and disseminated a memorandum on Section 4302 of the Patient Protection and Affordable Care Act in relation to disability related data collection. (April 2011)
Medicaid Core Quality Measures (PDF)
We urged the Agency for Healthcare Research and to develop and include measures in the Core Set of Health Quality Measures for Medicaid-Eligible Adults that will improve the quality of care for people with disabilities. (March 1, 2011)
Health Information Technology
We responded to the Department of Health and Human Services, Office of the National Coordinator for Health Information Technology request for comments regarding Meaningful Use Stage 2. We urged the department to adopt explicit accessible information technology standards within stages 2 and 3 MU can both improve health outcomes for all patients with sensory, cognitive or mobility limitations, and to ensure that a technological system that has been mandated to reduce health disparities does not in itself act to replicate and deepen the disparities experienced by people with disabilities. (February 25, 2011)
New Definition of Medically Underserved Population (PDF)
We strongly urged The Health Resources and Services Administration to appoint several individuals with broad knowledge and awareness of health and health care disparities, barriers to care, and health outcomes experienced by individuals with diverse disabilities to the Negotiated Rulemaking Committee (NR) that will establish a comprehensive methodology and criteria for designation of Medically Underserved Populations (MUPS) and Health Professions Shortage Areas (HPSA). (June 9, 2010)