USAging Submits Comments on Proposed Discrimination RuleHHS's proposed rule implementing Section 1557 of the Affordable Care Act that prohibits discrimination on the basis of race, color, national origin, sex, age and disability in certain health programs and activities.
We support HHS's goal of advancing health equity and prohibiting discrimination in all HHS “health programs and activities.” We are also mindful of AAAs' historic and ongoing commitment to prevent discrimination in the delivery of programs and services, as well as AAAs' expanding role into what could be considered “health programs and activities.”
Our comments sought to:
- Clarify Section 1557 language regarding notice of nondiscrimination and notice of availability of language assistance services and auxiliary aids and services, as well as the designation of a Section 1557 Coordinator position. Specifically, consideration of funds needed to support compliance for requirements to provide information in the top 15 languages and the position of a coordinator when applicable. HHS must provide clarification as to how smaller health care and health-related entities might be supported to meet the requirements of this regulation.
- Support the provisions reinstating prohibitions on discrimination based on sexual orientation and gender identity in Programs for All-Inclusive Care for the Elderly (PACE) and Medicaid.
- Support the telehealth provisions while cautioning policymakers to understand that further investment and support will be needed to ensure older adults aren't left behind because of technology challenges or limitations.