March 7, 2022
DREDF, in collaboration with the Community Living Policy Center at the Lurie Institute for Disability Policy at Brandeis University submitted comments to the Centers for Medicare & Medicaid Services (CMS) on proposed changes to regulation of Dual-Eligible Special Needs Plans (D-SNPs) as part of a larger rulemaking on Medicare Part C & D. We support the direction of CMS’s proposals and appreciate the efforts to tighten and clarify requirements and the focus on enrollee experience and needs. Our comments primarily explore areas where we believe that CMS could include further specificity in the regulations such as advisory committees, network adequacy, durable medical equipment, and home health care. These regulations are important given the rapid growth of D-SNPs across the country. [...]

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. [...}