DREDF Comments

DREDF responds to CMS Innovation Center’s RFI

November 21, 2017
The Centers for Medicare and Medicaid Services Innovation Center (CMMI) put out an informal Request for Information on September 20, seeking stakeholder feedback on a "new direction to promote patient-centered care and test market-driven reforms." The RFI emphasizes choice and competition as the keys to higher quality, reduced costs, and improved patient outcomes. DREDF response emphasizes the critical need for enhancing and integrating long-term services and supports across all of CMMI's models, including within accountable care organizations, advance payment models, and PACE programs for younger people with disabilities

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DREDF Supports CMS Proposed Revisions to Payment Policies Under the CMS Physician Fee Schedule

October 5, 2017
Re: Revisions to Payment Policies under the Physician Fee Schedule and other Revisions to Part B for CY 2018; Medicare Shared Savings Program Requirements; and Medicare Diabetes Prevention Program (CMS-1676-P)

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DREDF Objects to the Massachusetts Request to Eliminate Non-Emergency Medical Transportation

October 4, 2017
It has been very difficult to obtain actual data to establish the numbers of people with disabilities among the Medicaid expansion population, given the dearth of both tracked disability-related questions and optional demographic information on disability in the streamlined  enrollment application.  Nonetheless, we submit that many working low-income people with disabilities, including individuals with multiple chronic conditions such as heart disease and diabetes who may not typical identify as a person with a disability, have enrolled in Medicaid through the expansion option.  Consequently, we are deeply concerned by the proposal to eliminate the non-emergency medical transportation (NEMT) benefit for MassHealth CarePlus enrollees, otherwise known as the Medicaid expansion population, except for transportation for substance use disorder (SUD)-related services.

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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.

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DREDF’s Comments on CMS Proposals

July 5, 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."

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

April 4, 2016
All consumers need clear and accessible information. For consumers with disabilities, however, these needs become quite specific. That is, coverage information about such topics as the treatment of habilitation services and devices durable medical equipment, orthotics and prosthetics, prescription drugs, and mental health coverage is particularly important since these are items that enable people with chronic conditions and disabilities to remain functional in their lives and communities.

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DREDF Comments on Proposed Rule – Genetic Information Nondiscrimination Act

January 30, 2016
DREDF opposes the proposed rule as a clear erosion of GINA's protections against disclosure of disability-related information by employees and their family members. The Commission's proposed rule disregards the plain language and stated purpose of GINA, recorded in Congressional history and statements, and the regulations already that the EEOC has already promulgated under GINA. Ultimately, a weakened GINA rule, in concert with the expanding promulgation of untested employer wellness programs, will easily and inevitably lead to adverse employment decisions based on fears about the cost of insuring an employer and his or her dependents.

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Federal Marketplace Benefit and Payment Parameters for 2017

January 15, 2016
DREDF commented on a large set of proposed regulations issued by the Centers for Medicare and Medicaid (CMS) shortly before the holidays. The draft regulations concerned Benefit and Payment Parameters for qualified health plans in the federal marketplace in 2017. In our comments, DREDF highlighted concerns with QHP's coverage of rehabilitative devices and durable medical equipment as rehabilitative benefits, and ongoing shortfalls in network adequacy standards with respect to physical and programmatic accessibility.

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

November 18, 2015
As an organization founded by people with disabilities and parents of children with disabilities, we have long advocated for equally effective and barrier-free healthcare for people with disabilities of all ages. We strongly support the repeal of the Medicare sustainable growth rate (SGR) methodology for updating the physician fee schedule (PFS) effected by Section 101 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), and its replacement with a new Merit-based Incentive Payment System (MIPS).

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