Comment Letter: Protections Against Discrimination Needed in Medical Care and Value Assessment
Published November 15, 2023
On November 13, 2023, the Alliance was joined by 44 organizations to ask the Department of Health and Human Services (HHS) to strength protections against discrimination in healthcare decision making and in value assessment.
The letter was submitted in response to proposed regulation from the HHS Office of Civil Rights (OCR) that updates, clarifies, and strengthens the implementing regulation for Section 504 of the Rehabilitation Act of 1973. The proposed rule proposes to update the current Section 504 regulations to clarify several crucial areas not explicitly addressed in that rule.
The groups’ response to the agency supports the OCR’s efforts to strength protections for people with disabilities, calls for enhanced protections for older adults, and highlights the intersectionality of age and disability-related discrimination. The letter also stresses the need for clear language regarding value assessment methodologies to prevent discriminatory impacts stemming from the use of metrics such as the quality-adjusted life year (QALY) and estimated value of life years gained (evLYG).