Public Comments

DREDF Submitted Comments to CMS Against Tennessee’s Proposal to Block Grant its Medicaid Program

January 2, 2020
DREDF submitted comments to the Centers for Medicare and Medicaid Services against the state of Tennessee’s proposal to fundamentally alter how the state’s Medicaid program is funded, going from a program that must provide healthcare services, with matching federal support, to all eligible low-income persons in Tennessee to a program where the state can only rely on a set federal grant and is allowed to impose additional limitations on Medicaid-eligible Tennesseans. Tennessee has consistently proposed changes over the last few years to its Medicaid program that would be harmful to low-income persons with disabilities and chronic conditions. [...]

DREDF Submitted Comments December 17 Against a Proposed HHS Grants Federal Rule

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January 2, 2020
DREDF submitted comments December 17 advocating against a proposed federal rule that would allow the many entities that receive grants from the federal Health and Human Services agency (HHS) to discriminate on the basis of sexual orientation, gender identity, or religion in their programs and activities. HHS gives billions of dollars to organizations that deliver healthcare and social services in areas such as adoption, addiction recovery, and medical research. People with disabilities who are LGBTQ+ or who hold a particular religious faith are at risk of being denied participation in needed health services and supports from federally-funded private organizations that would be free to discriminate against certain clients and patients. [...]

DREDF Response Comments on CPUC Intentional Power Outage Proceeding

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October 29, 2019
On October 15, 2019, DREDF filed our response comments as part of the second phase of the California Public Utilities Commission regulatory proceedings on Investor Owned Utility decisions to shut off power to consumers during extreme weather events. DREDF is deeply concerned that the Investor Owned Utilities are not doing nearly enough to meet the needs of the disability community during all stages of these intentional power outages. DREDF will continue to be involved in a multi-prong approach to address the current inadequacies of the intentional power outage process.

DREDF’s Comments in Opposition to HUD’s Proposed Changes to the “Disparate Impact” Rule

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October 23, 2019 On October 18, 2019 DREDF submitted comments in opposition to the U.S. Department of Housing and Urban Development’s (HUD’s) proposed changes to the “Disparate Impact” rule. DREDF urged the Department to withdraw the rule in its entirety. HUD’s Proposed Rule would impose drastic changes to the Fair Housing Act’s “disparate impact” protections. These changes would make it much more difficult to use HUD’s Disparate Impact rule to challenge policies and practices that disproportionately harm people with disabilities.

DREDF Comments on Proposed Changes to the Section 1557 Regulations

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August 13, 2019
DREDF is gravely concerned with HHS' proposed amendments to the Section 1557 regulations. While we appreciate that HHS seeks to reduce costs and improve health plan sustainability, these goals cannot be sought at the expense of the civil rights of health care consumers—and particularly those individuals and families who already face pervasive physical, programmatic, and attitudinal barriers in the health care context.

DREDF and Disability Rights California comment on the California Department of Health Care Services draft update for the Facility Site Review (FSR) and Medical Record Review (MRR) Survey Tools and Guidelines

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May 29, 2019
DREDF submitted comments on May 29, 2019 in response to the California Department of Health Care Services (DHCS), Managed Care Quality and Monitoring Division (MCQMD) draft update for the Facility Site Review (FSR) and Medical Record Review (MRR) Survey Tools and Guidelines. The FSR and MRR survey tools and their associated guidelines set forth important measures that directly relate to barriers that affect the health and wellbeing of disabled individuals in California who receive health care through managed care organizations (MCOs). However, the ability of MCO's to collect needed information, and synthesize and report it accurately depends both on the clarity of the survey instruments and the categories of information being collected. Thus, we asked DHCS to consider several substantive additions to the FSR and MMR tools and guidelines. Our comments also responded to the 2019 drafts as compared with the survey tools and guidelines found in DHCS Policy Letter 14 – 004.

DREDF Comments on Tennessee’s Proposal for a Section 1115 Medicaid Waiver

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February 7, 2019
DREDF submitted comments on February 7, 2019 in response to Tennessee’s proposal for a Section 1115 Medicaid Waiver that would allow the State to impose work requirements in its Medicaid program. DREDF, along with many other disability and healthcare advocacy organizations, unequivocally oppose this proposal and believe the changes would run counter to Medicaid’s core purpose to furnish medical assistance on behalf of people with insufficient income and resources to meet the costs of medically necessary care and to provide rehabilitation and other services to help families and individuals attain or retain capacity for independence or self-care. While Tennessee’s waiver application purports to contain exceptions for limited categories of people with disabilities, the very short proposal does not define or establish standards for these categories or indicate how the State would apply any exceptions. Our comments support our opposition to the proposal with research and analysis.

DREDF Comments on Medicaid Managed Care Rule

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January 17, 2019 DREDF submitted comments January 14, 2019 on proposed changes to the federal regulations currently governing managed care organizations that deliver Medicaid services. The Centers for Medicare and Medicaid want to streamline and reduce the “regulatory burden” of the current rule on states that administer Medicaid. DREDF’s comments argue against proposed cut backs on requirements for communication accessibility and network adequacy.

DREDF’s Comment on the Public Charge Proposed Rule

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December 10, 2018
Over 210,000 comments were sent to the Department of Homeland Security on its proposed notice regarding Inadmissibility on Public Charge Grounds. DREDF's comment speaks against the proposed changes and reflects our advocacy on behalf of all persons with disabilities, whether they are Americans or seek the opportunity to come and contribute to this country.

DREDF Comments in Response to National Park Service Proposed Rulemaking Regarding Special Events and Demonstrations in the National Capital Region

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October 17, 2018
DREDF submitted comments October 15, 2018 in response to National Park Service proposed rulemaking regarding special events and demonstrations in the National Capital Region. DREDF strongly opposed the rules which would restrict constitutional rights to free speech by limiting access to the White House sidewalk, assessing fees, and limiting rapid response actions.