DREDF Comments

Proposed Accessibility Standards for Medical Diagnostic Equipment

June 8, 2012
Although the proposed technical criteria are intended to address most of the barriers that have been identified as affecting the accessibility and usability of medical diagnostic equipment, not every barrier is addressed in the proposed standards.

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California’s Dual Eligibles Demonstration

May 8, 2012
Dual eligibles will be passively enrolled in Medicare. Individuals who do not actively opt out of the demonstration will be locked in to a particular health plan for 6 months. Enrollees are left to rely upon a 6 month care continuity option, that does not appear to extend to such critical ancillary providers as Durable Medical Equipment (DME) suppliers and seating fitters, and a Medi-Cal Medical Exemptions Request (MER) process that has been fraught with interpretation and implementation difficulties during the mandatory enrollment of seniors and persons with disabilities under the 1115 waiver.

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EHR Standards and Certification Criteria

May 7, 2012
In the proposed rules for Stage 2, we were similarly troubled to see CMS state that: However, providers should be aware that while meaningful use is limited to the capabilities of CEHRT to provide online access there may be patients who cannot access their EHRs electronically because of their disability.

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Establishment of Exchanges and Qualified Health Plans

October 31, 2011
In light of these outstanding concerns, it is critical that state Exchanges adhere to the following requirements which address additional concerns in specific subject areas relating to consumer representation, physical and programmatic accessibility in both healthcare delivery and procedural protections, and data collection.

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Proposed ACA Data Collection Standards

August 1, 2011
In addition to calling for collection of data on disability status for applicants, recipients, or participants by any federally conducted or supported health care or public health program, activity or survey, Section 4302 of the ACA also requires the collection of additional information related to specific, known barriers to healthcare that affect individuals with disabilities and that contribute to the health and health care disparities they experience, and sets forth the following specific data collection standards:

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