Essential Health Benefits Bulletin

February 12, 2012
Thank you for the opportunity to comment on the Essential Health Benefits (EHB) Bulletin released December 16, 2011 by the Center for Consumer Information and Insurance Oversight.

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.

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:

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).

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:

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.

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).