October 3, 2022

On October 3, APMA submitted comments to HHS and the Office of Civil Rights (OCR) in response to proposals related to Section 1557 and nondiscrimination in health programs and activities. APMA supports the ultimate goal of HHS to ensure that patients do not face discrimination based on race, color, national origin, age, disability, or sex, especially as they are fundamental to advancing health equity. However, we expressed our significant concerns as to how these proposals, if implemented as currently drafted, would impact overly burdened providers, especially if HHS included small or solo practices. APMA recommends that HHS not finalize the proposals as drafted, but if it does, we request it minimize the burdens created by developing and making available the following materials, free of charge:

• Template Section 1557 policies and procedures that podiatric physicians’ offices of various sizes and complexity can use to fulfill finalized policies requiring the development and implementation of policies and procedures, including, but not limited to a nondiscrimination policy, grievance procedures, language access procedures, effective communication procedures, and procedures for reasonable modifications for individuals with disabilities;
• Section 1557 educational materials and training resources, including materials that practices could use to train employees and test their understanding of the new requirements and how to comply; and
• patient notices and other patient education materials that practices can disseminate to patients and display in their offices.

Members may read this letter and all past comment letters at www.apma.org/commentletters. If you have any questions or concerns, contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.

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