DREDF Comments

Accountable Care Organizations

June 6, 2011
The Disability Rights Education and Defense Fund (DREDF) and Access Living, along with the undersigned organizations and individuals, appreciate the opportunity to comment on the proposed rule regarding Medicare Shared Savings Program: Accountable Care Organizations (ACOs).

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Opposition to SB 462

April 25, 2011
SB 462 proposes a voluntary certification process for non-attorney, paid or unpaid special education advocates who want to participate in IEPs or mediations. The bill would require special education local plan areas to provide alternative dispute resolution training, and the Office of Administrative Hearings to administer a test, to persons seeking certification. The bill would require a fee for the training and testing, and would also require advocates to disclose detailed information about their advocacy, areas of expertise, as well as personal relationship with the parent or child.

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Health Disparity Research and Data Collection

April 25, 2011
Section 4302 of the ACA mandates the 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.” In addition, section 4302 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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Health Information Technology

February 25, 2011
While we were disappointed that accessibility standards were not included in HHS’s July 2010 final rule establishing stage 1 “meaningful use,” we are encouraged by the Department’s inclusion of disability specific questions in its latest request for comments. We strongly urge the Department to adopt explicit accessible information technology standards within stages 2 and 3 MU to both improve health outcomes for all patients with sensory, cognitive or mobility limitations, and to ensure that a technological system that has been mandated to reduce health disparities does not in itself act to replicate and deepen the disparities experienced by people with disabilities.

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Final Comments on Advance Notices of Proposed Rulemaking (ANPRMs)

January 1, 2011
DREDF welcomes the opportunity to provide detailed, targeted responses to the questions posed by the Department in its four recent Advance Notices of Proposed Rulemaking (ANPRMs) to amend regulations issued under the Americans with Disabilities Act (ADA)

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Health Resources and Services Administration

June 9, 2010
We strongly urge you to appoint several individuals with broad knowledge and awareness of health and health care disparities, barriers to care, and health outcomes experienced by individuals with diverse disabilities to the Negotiated Rulemaking Committee (NR) that will establish a comprehensive methodology and criteria for designation of Medically Underserved Populations (MUPS) and Health Professions Shortage Areas (HPSA).

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EEOC Proposed ADAAA Regulations

November 23, 2009
The Disability Rights Education and Defense Fund, Inc. (DREDF) appreciates the opportunity to comment on the Equal Employment Opportunity Commission (EEOC) proposed Regulations to Implement the Equal Employment Provisions of the Americans with Disabilities Act (ADA), as Amended.

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USDOT Notice of Proposed Rulemaking, ADA

June 3, 2006
DOT is proposing to add to its regulation a provision requiring ADA transportation providers to make reasonable modifications to policies, practices, and procedures when necessary to avoid discrimination on the basis of disability, unless the transit agency can show that the modifications would fundamentally alter the nature of the service or activity, or would result in undue administrative or financial burdens or a direct threat to the health and safety of others.

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