Public Comments

DREDF responds to CMS request for information on new system for paying Medicare providers.

November 18, 2015
As an organization founded by people with disabilities and parents of children with disabilities, we have long advocated for equally effective and barrier-free healthcare for people with disabilities of all ages. We strongly support the repeal of the Medicare sustainable growth rate (SGR) methodology for updating the physician fee schedule (PFS) effected by Section 101 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), and its replacement with a new Merit-based Incentive Payment System (MIPS).

Affordable Care Act Section 1557 Notice of Proposed Rulemaking

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November 13, 2015
DREDF submitted comments on proposed regulations issued under Section 1557 of the Affordable Care Act, on non-discrimination in federally funded and federally conducted healthcare activities and programs such as Medicaid, Medicare, and the federal and state marketplaces.

DREDF comments on CMS’s proposed new rule for Medicaid Managed Care submitted 7/27/15

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July 27, 2015
DREDF has submitted comments focusing on those aspects of the rule that deal with accessibility for people with disabilities and provider network adequacy, as well as some additional topics of particular concern to the disability community.

Comments on Updated California Reporting Requirements

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June 30, 2015
DREDF submitted comments on the updated California State-Specific Reporting Requirements for Contract Year 2015, released by the Centers for Medicare and Medicaid Services (CMS) June 22, 2015.

DREDF Comments on Proposed Rule Concerning Medicaid

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June 11, 2015
DREDF comments on proposed rule concerning Medicaid, Children's Health Insurance Programs; Mental Health Parity and Addiction Equity Act of 2008; the Application of Mental Health Parity Requirements to Coverage Offered by Medicaid Managed Care Organizations, the Children's Health Insurance Program (CHIP), and Alternative Benefit Plans, RIN 0938-AS24.

Draft FTA ADA Circular: DREDF submits detailed comments

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February 9, 2015
DREDF comments on the draft Federal Transit Administration (FTA) Americans with Disabilities Act (ADA) Circular, Amendment 2, are now available.

Comments on Federal Health IT Strategic Plan 2015-2020

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February 6, 2015
DREDF commented on the urgent need to track disability status, specific functional impairment, and reasonable accommodation or policy modifications needed as a first critical step needed to measure and understand the health disparities experienced by people with disabilities.

Recommendations for Changes to NAIC’s Network Adequacy Model Act

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January 12, 2015
We urged NAIC to strengthen its proposed Network Adequacy Model Act by calling for physical and programmatic access criteria to be included in evaluating the capacity of health care provider networks to adequately serve diverse patient populations.

Comments on Notice of Benefit and Payment Parameters for 2016

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December 26, 2014
DREDF submitted comments on HHS proposed rules affecting implementation of portions of the Affordable Care Act that directly affect people with disabilities. In addition to supporting comments submitted by the Consortium for Citizens with Disabilities (CCD), we urged HHS to issue comprehensive language access standards and technical support for navigator and non-navigator assistance personnel to ensure that people with communication disabilities have equal access to the Health Insurance Marketplace.

Comments on California HCBS Statewide Transition Plan

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October 27, 2014
Update: On December 8, 2014 DREDF and a number of other advocacy organizations (CFILC, California's SCDD, Congress of California Seniors, DRC, NHeLP, and NSCLC) submitted a second set of comments on the latest draft of California's HCBS transition plan. California is expected to submit it's final HCBS transition plan to the federal Centers for Medicare and Medicaid Services by December 19 or so.