Public Comments

DREDF Submits Comments Opposing CMS’ Proposed Narrowing of Nursing Home Screening Requirements

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June 4, 2020
On May 20, DREDF submitted comments opposing a proposed rule from CMS that would have the effect of narrowing the applicability of the Preadmission Screening and Resident Review (PASRR) that nursing homes must administer to individuals with mental, intellectual or developmental disabilities to prevent their inappropriate and unwanted institutionalization. The comments point out that the PASRR rules should be updated to require broader review in light of legal and social trends toward community placement and away from segregated care, and highlight the inappropriateness of the proposed rule in light of the clear threat to life posed by nursing home residence during the current COVID-19 pandemic. [...]

DREDF Comments on HHS’s Proposed Rule for Medicare Parts C and D 2021/22

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April 6, 2020
DREDF submitted targeted comments on the Centers for Medicare and Medicaid Services’ (CMS’) proposed rule for Contract Year 2021 and 2022 on Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (the Proposed Rule). There are a significant number of people with disabilities who are Medicare enrollees, some of whom are also dually eligible for Medicaid. We have focused our comments primarily on revisions to supplemental benefits for beneficiaries with chronic conditions, network adequacy, D-SNP Look-Alike Plans, and Real-Time Benefit Tools. [...]

DREDF Comments on USDOT Traveling by Air with Service and Emotional Support Animals Rule

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April 7, 2020
The Department's NPRM is the latest iteration of those efforts. In our comments, we respond to the Department's specific questions and proposed regulatory language. Our comments referencing "service animals" refer to an animal trained to perform specific work or tasks to mitigate the effects of a disability. The term "emotional support animal" refers to an animal whose presence and untrained supportive behaviors assist a person with a disability. [...]

DREDF Comments on HUD Affirmatively Furthering Fair Housing Proposed Rule

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March 16, 2020
DREDF submitted comments March 16 to the Department of Housing and Urban Development’s (HUD) proposed rule to weaken the 2015 Affirmatively Furthering Fair Housing (AFFH) rule in an effort to reverse government progress on discriminatory housing practices. The proposal affects people with disabilities and communities of color by allowing local jurisdictions to leave unaddressed fundamental disability and racial segregation obligations of fair housing law. DREDF urges HUD to uphold its commitment to Affirmatively Furthering Fair Housing for people with disabilities and other covered classes, and to withdraw this proposed rule in its entirety and reinstate the 2015 AFFH Rule. [...]

DREDF Comments on HHS Notice of Benefit and Payment Parameters for 2021

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March 2, 2020
DREDF submitted comments to HHS on proposed rules that would affect the implementation of sections of the Affordable Care Act (“ACA”) that directly affect people with disabilities. In our comments, we urge HHS to withdraw proposals that would weaken the ACA’s “Essential Health Benefit” provisions, impose new financial reporting burdens on healthcare marketplace consumers, and make it more difficult for consumers to pay for prescription drugs. We also urged HHS to not expand the use of discriminatory “wellness programs” in health plans in the individual market. Finally, we supported HHS’ proposal to expand the availability of special enrollment periods for health care consumers. [...]

Autonomous Vehicles: Promises and Challenges of Evolving Automotive Technologies

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February 11, 2020
Autonomous Vehicles have the potential to drastically improve mobility for people with disabilities. However, the promise and safety of AVs will only be realized if the vehicles and the surrounding infrastructure are fully accessible, ie, accessible to people with sensory, cognitive, and physical disabilities, including wheelchair users, and people with neurological conditions, including seizure disorders. The safety elements such as the human machine interfaces and securement must also consider the needs of all people with disabilities. [...]

DREDF Comments Regarding Issues Addressed in a Bicameral, Bipartisan AV Bill

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February 6, 2020
Nearly 1 in 5 people in the U.S. has a disability (more than 57 million). In 1990, Congress passed the bipartisan Americans with Disabilities Act (ADA). In enacting the ADA, Congress sought to "provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities." As a result, 99% of public buses are equipped with ramps, far more curb ramps benefit the public, and there is improved provision of accessible transit to people with sensory disabilities. Yet, significant barriers to accessible, affordable transportation remain across modes. [...]

DREDF Submitted Comments to the USDOT AV Inclusive Design Challenge RFI

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February 6, 2020
DREDF submitted comments in response to the USDOT AV Inclusive Design Challenge Request for Information. Ensuring access is easier, and cheaper in the long run, if it is integrated at the outset. Yet, news accounts of AV testing and deployment timelines often fail to mention accessibility. DREDF knows well that if access is not baked into technology, history will likely be repeated. Accessible vehicles will be needed, and retrofitting will be more expensive for providers in the long run. DREDF supported the design challenge, and encouraged USDOT to require applicants to engage with disability advisors and hire disabled professionals for their projects. DREDF recommended priority be given to fully inclusive vehicle designs. [...]

DREDF Submitted Comments January 31 on Proposed SSA Rule to Increase Continuing Disability Reviews

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February 4, 2020
DREDF submitted comments January 31 advocating against a proposed federal rule that would allow the Social Security Administration to increase how often many who are receiving Social Security disability benefits would have to undergo review for a continuing disability. Currently, people with disabilities have routine disability reviews or at set intervals to maintain their benefit eligibility. Under the proposed rule, SSA would review most people every two years. Not only is this review process extremely stressful and burdensome for people with disabilities, disability policy experts calculate that 2.6 million people, many of whom remain eligible, could be at risk of losing benefits with implementation of this new policy. The proposed rule would disproportionately harm adults nearing retirement age, children, people with serious behavioral health disabilities, and people who have cancer. DREDF urges SSA to withdraw this rule immediately. [...]

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