April 27, 2023
DREDF submitted comments to OMB on its initial proposal to update Statistical Policy Directive 15 on Race and Ethnicity Statistical Standards. The comments recognize that the proposed changes will mean a break with how race/ethnicity data has been previously collected and could make analysis over time difficult. However, DREDF agrees that it is critically important to ask for information about individuals and all their characteristics, including having a disability, in ways that center how people see themselves and uses language they understand.
Author: silvia
This Data Not That Data: Big Data, Privacy, and the Impact on People with Disabilities
March 28, 2023
The consequences of people with disabilities not being counted among those who are capable of good health results in a self-fulfilling prophecy that ensures disabled people can rarely achieve good health.
Comments Providing Information for Better Capturing People With Disabilities in U.S. Census Surveillance
November 15, 2022
While DREDF is encouraged by state actions to equitably recognize their full disability population and more accurately capture their needs, we call on the Census Bureau to both follow the possibilities of what states have done and assume a leadership role in setting a new national standard for disability population data collection. We make the following recommendations…
DREDF Comments on the 2022 Section 1557 Proposed Rule on Nondiscrimination in Health Programs and Activities
October 3, 2022
DREDF strongly supports the proposed rule. It clarifies and strengthens nondiscrimination protections for people with disabilities and other populations that have experienced systemic barriers to receiving equally effective health care. Below we provide a more detailed section-by-section analysis of how particular provisions in the proposed rule will benefit the health and well-being of our communities. […]
DREDF Supports Discussion Draft of Legislation Making Medicaid Home and Community-Based Services Mandatory
April 27, 2021
Senators Hassan, Brown and Casey, and Representative Dingell, released a discussion draft of the Home and Community-Based Services Access Act (HAA) in mid-March, seeking broad stakeholder comment. The federal HAA is in an early form but addresses a long-sought goal of the disability community to require states to offer home and community-based services and not only institutional nursing home care under Medicaid. This requirement would help eliminate the waiting lists and patchwork of eligibility and services that Medicaid beneficiaries with long-term care needs currently have to navigate. The HAA also tries to establish living wages and working conditions for the HCBS workforce that will help ensure stable HCBS for all eligible Medicaid enrollees who want HCBS. DREDF worked with the Consortium of Citizens for Disabilities to submit a detailed set of joint comments and also a shorter DREDF set of specific additional comments.[…]
DREDF Policy Recommendations for Reducing COVID-19 Nursing Home Deaths Through Innovative HCBS
June 4, 2020
On May 21, DREDF submitted data and policy information on several innovative home and community-based projects that could help reduce the steep rates of COVID-19 infection and death of disabled and older persons in nursing homes and other institutions throughout the U.S. Our submission recommends fostering partnerships among health plans, state and local entities, disability organizations, aging organizations, and health and home and community-based service providers to fill the service and support gaps experienced by people with disabilities of all ages who are sheltering in place in their communities. We equally emphasize the importance of data collection on where, when, and how people with disabilities and older persons are experiencing COVID-19 infections and deaths. […]
DREDF Submits Comments Opposing CMS’ Proposed Narrowing of Nursing Home Screening Requirements
June 4, 2020
On May 20, DREDF submitted comments opposing a proposed rule from CMS that would have the effect of narrowing the applicability of the Preadmission Screening and Resident Review (PASRR) that nursing homes must administer to individuals with mental, intellectual or developmental disabilities to prevent their inappropriate and unwanted institutionalization. The comments point out that the PASRR rules should be updated to require broader review in light of legal and social trends toward community placement and away from segregated care, and highlight the inappropriateness of the proposed rule in light of the clear threat to life posed by nursing home residence during the current COVID-19 pandemic. […]
DREDF Comments on HHS’s Proposed Rule for Medicare Parts C and D 2021/22
April 6, 2020
DREDF submitted targeted comments on the Centers for Medicare and Medicaid Services’ (CMS’) proposed rule for Contract Year 2021 and 2022 on Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (the Proposed Rule). There are a significant number of people with disabilities who are Medicare enrollees, some of whom are also dually eligible for Medicaid. We have focused our comments primarily on revisions to supplemental benefits for beneficiaries with chronic conditions, network adequacy, D-SNP Look-Alike Plans, and Real-Time Benefit Tools. […]
DREDF Comments on Medicaid Managed Care Rule
January 17, 2019
DREDF submitted comments January 14, 2019 on proposed changes to the federal regulations currently governing managed care organizations that deliver Medicaid services. The Centers for Medicare and Medicaid want to streamline and reduce the “regulatory burden” of the current rule on states that administer Medicaid. DREDF’s comments argue against proposed cut backs on requirements for communication accessibility and network adequacy.
DREDF’s Comment on the Public Charge Proposed Rule
December 10, 2018
Over 210,000 comments were sent to the Department of Homeland Security on its proposed notice regarding Inadmissibility on Public Charge Grounds. DREDF’s comment speaks against the proposed changes and reflects our advocacy on behalf of all persons with disabilities, whether they are Americans or seek the opportunity to come and contribute to this country.