December 26, 2012
DREDF Submits Comments on Proposed Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation under the Patient Protection and Affordable Care Act
Public Comments
DREDF comments on the State Option to Provide (HCBS)
July 23, 2012
DREDF comments on the State Option to Provide Home and Community-Based Services (HCBS) for Medicaid-eligible individuals.
Proposed Rule for State Plan HCBS
July 2, 2012
DREDF has read and agrees with both the overarching and more specific comments of our colleagues at both the Bazelon Center for Mental Health Law and the National Disability Rights Network concerning the proposed Rule. Our chief concerns and recommendations are as follows: ...
Comments on Proposed Rule for State Plan HCBS
July 2, 2012
DREDF comments on the State Option to Provide Home and Community-Based Services (HCBS) for Medicaid-eligible individuals.
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.
California’s Dual Eligibles Demonstration
May 8, 2012
Much of the language of California’s draft proposal is familiar from the stakeholder process, and laudable in its broad outlines. The state has consistently reiterated having the goals of coordinating state and federal public health care benefits for dual eligible, improving the availability and delivery of home- and community-based services (HCBS), preserving self-directed consumer care, and optimizing Medicare, Medi-Cal and state/county resources.
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.
Department of Labor’s Proposed Regulations
March 21, 2012
Re: Comments on the Wage and Hour Division, Department of Labor's Proposed Regulations Re: Application of the FLSA to Domestic Service, 78 Fed. Reg. 81190 Dec. 27, 2011
Regulatory Information Number 1235-AA05
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.