DREDF Comments

DREDF and Allies Submit Comments on Website Accessibility

October 21, 2016
On October 7, 2016, in response to the U.S. Department of Justice’s Supplemental Notice of Proposed Rule regarding Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government, DREDF has signed onto comments submitted by the National Federation of the Blind (NFB); National Association of the Deaf (NAD); National Disability Rights Network; and Paralyzed Veterans of America, among others. The comments emphasize that the internet has become a fundamental part of every day life, and state and local government websites must remove the serious barriers facing people with disabilities in accessing critical government information online.

DREDF’s Comments on CMS Proposals

June 27, 2016

DREDF supports CMS proposals to include Promoting Health Equity and Continuity, and Social and Community Involvement as Clinical Practice Improvement Activity performance categories related to rewarding eligible practitioners who work to improve and maintain high quality care for people with disabilities. However, we question why the proposed rule fails to immediately adopt the subcategory of promoting health equity, which explicitly includes “maintaining adequate equipment and other accommodations.”

Summary of Benefits and Coverage and Uniform Glossary (CMS–10407)

March 28, 2016

Delivered via Electronic Mail to: OIRA_submission@omb.eop.gov; DOL_PRA_PUBLIC@dol.gov; PRA@treasury.gov;
Paperwork@cms.hhs.gov

Mr. Howard Shelanski
Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
Executive Office of the President
725 17th Street, NW
Washington, DC 20503

RE: Summary of Benefits and Coverage and Uniform Glossary (CMS–10407)

Dear Administrator Shelanski:
Continue reading Summary of Benefits and Coverage and Uniform Glossary (CMS–10407)

DREDF Comments on Proposed Rule – Genetic Information Nondiscrimination Act

January 28, 2016                            

Submitted electronically to www.regulations.gov

Bernadette Wilson
Acting Executive Officer
U.S. Equal Employment Opportunity Commission
131 M Street NE
Washington DC 20507

Re:   Comments on Proposed Rule, Genetic Information Nondiscrimination Act, RIN 3046–AB02
Continue reading DREDF Comments on Proposed Rule – Genetic Information Nondiscrimination Act

Federal Marketplace Benefit and Payment Parameters for 2017

December 21, 2015

Via online submission to www.regulations.gov

Andrew Slavitt
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-9937-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE: CMS-9937-P; Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017 (RIN 0938—AS57)
Continue reading Federal Marketplace Benefit and Payment Parameters for 2017

DREDF responds to CMS request for information on new system for paying Medicare providers.

November 17, 2015

Via online submission to www.regulations.gov

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Room 445-G, Hubert H. Humphrey Building,
200 Independence Avenue, SW.
Washington, DC 20201
Continue reading DREDF responds to CMS request for information on new system for paying Medicare providers.

Affordable Care Act Section 1557 Notice of Proposed Rulemaking

November 9, 2015

Via online submission to www.regulations.gov

Ms. Jocelyn Samuels
Director, Office for Civil Rights
U.S. Department of Health and Human Services
Attn: 1557 NPRM (RIN 0945-AA02)
Hubert H. Humphrey Building
200 Independence Avenue SW
Washington, DC 20201
Continue reading Affordable Care Act Section 1557 Notice of Proposed Rulemaking

DREDF comments on CMS’s proposed new rule for Medicaid Managed Care submitted 7/27/15

July 27, 2015 Via electronic submission to regulations.gov

Andy Slavitt
Acting Administrator
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS-2390-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: CMS-2390-P Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability

Disability Rights Education and Defense Fund (DREDF) appreciates the opportunity to provide comments to the Centers for Medicare and Medicaid (CMS) on its proposed rule for the Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability (Medicaid managed care rule). DREDF is a leading national law and policy center that works to advance the civil and human rights of people with disabilities through legal advocacy, training, education, and public policy and legislative development. We are committed to increasing access to equally effective healthcare for people with disabilities, and eliminating persistent physical and programmatic barriers and healthcare disparities that adversely affect the length and quality of their lives.
Continue reading DREDF comments on CMS’s proposed new rule for Medicaid Managed Care submitted 7/27/15

Comments on Updated California Reporting Requirements

June 29, 2015

Sent via electronic mail to
Medicare-Medicaid Coordination Office, MMCOCapsModel@cms.hhs.gov
Tracy Meeker, DHCS, Tracy.Meeker@dhcs.ca.gov

Re: Comments on Updated CA Reporting Requirements

Dear Sirs or Madams:

Disability Rights Education and Defense Fund (DREDF) appreciates the opportunity to submit comments on the updated California State-Specific Reporting Requirements for Contract Year 2015, released by the Centers for Medicare and Medicaid Services (CMS) June 22, 2015. Our comments below are directed primarily at the newly added physical accessibility requirements in Measure CA3.1. With regard to other newly added requirements, we support the comments submitted by our colleagues at Justice in Aging with regard to plan reporting of HRA and ICP completion, as well as their comments on the need for additional measures on rebalancing and person-centered care. Please note that while our own comments provide greater elaboration on Measure CA3.1, our two organizations are in fundamental alignment on the subject.
Continue reading Comments on Updated California Reporting Requirements

DREDF Comments on Proposed Rule Concerning Medicaid

June 9, 2015

Via submission to www.regulations.gov

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8016
Baltimore, MD 21244-8016

Re: Proposed Rule concerning Medicaid, Children’s Health Insurance Programs; Mental Health Parity and Addiction Equity Act of 2008; the Application of Mental Health Parity Requirements to Coverage Offered by Medicaid Managed Care Organizations, the Children’s Health Insurance Program (CHIP), and Alternative Benefit Plans, RIN 0938-AS24

Continue reading DREDF Comments on Proposed Rule Concerning Medicaid