NADP Comments on Nondiscrimination Rule
For more on the proposed rule, HHS provided a Fact Sheet and summary along with FAQs. In laying out recommendations, the NADP letter also includes more background on the proposed rule.
In brief, the proposed rule seeks to implement Section 1557 of the Affordable Care Act (ACA). As part of the rule, covered entities would be required to provide meaningful access to health programs for individuals with Limited English Proficiency (LEP) and ensure effective communications with individuals with disabilities. There are also standards for access to facilities and electronic and information technology. Covered entities, which could include insurers on Marketplaces, providers, nursing homes, labs, hospitals, Exchanges and state agencies, must also submit an assurance of compliance, designate an employee for compliance and adopt grievance procedures. A covered entity must post a notice in English regarding meaningful access and these procedures along with taglines in the top 15 languages spoken nationally regarding access to language assistance services.
NADP with volunteers from the Exchange Policy Workgroup (EPW), Government Relations Workgroup (GRW) and Commission on Advocacy Policy (CAP) developed specific recommendations, urging HHS to:
Thanks to all Government Relations volunteers who helped develop the comments—your input is invaluable and appreciated!