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.

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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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Affordable Care Act Section 1557 Notice of Proposed Rulemaking

November 13, 2015
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.

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

July 27, 2015
DREDF has submitted comments focusing on those aspects of the rule that deal with accessibility for people with disabilities and provider network adequacy, as well as some additional topics of particular concern to the disability community.

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DREDF Comments on Proposed Rule Concerning Medicaid

June 11, 2015
DREDF comments on 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.

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