January 27, 2022
DREDF and our colleagues at the Bazelon Center for Mental Health Law commented on all these aspects of the proposed rule. Non-discriminatory benefit design in healthcare is especially important for people with disabilities, including those with mental health disabilities, who have experienced both obvious and subtle discrimination in insurance for decades such as visit limits, "special" co-pays, and outright failure to cover services and items that are medically necessary for mostly people with disabilities. In our comments, we recommend that plan spending on improving health equity for people with disabilities, such as by helping providers to get accessible examination equipment, could and should be considered a quality improvement that doesn't count toward an insurer's profits. We also pointed out how telehealth has been inaccessible for people who are Deaf or who have other communications disabilities. Finally, we pushed for better demographic data collection on disability in healthcare overall. [...}