September 30, 2013
Department of Health and Human Services Office for Civil Rights
Attention: RIN 0945-ZA01
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, D.C. 20201
RE: Request for Information Regarding Nondiscrimination in Certain Health Programs or Activities RIN 0945-AA01
Dear Director Rodriguez:
The National Health Law Program (NHeLP) is a public interest law firm working to advance access to quality health care and protect the legal rights of low-income and underserved people. NHeLP provides technical support to direct legal services programs, community-based organizations, the private bar, providers and individuals who work to preserve a health care safety net for the millions of uninsured or underinsured low-income people. We are pleased to submit the following comments in response to the proposed rule issued on April 5, 2013 regarding standards for navigators and non-navigator personnel. NHeLP has been an ardent supporter of the Affordable Care Act’s (ACA’s) section 1557 on which this RFI is based and look forward to working with you and your staff on its implementation over the coming years.
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*NHeLP recognizes that the term “mental retardation” is offensive, outdated, and harms the disability community. NHeLP generally uses the term “intellectual disability.” However, this document uses the term “mental retardation” only to accurately conform to the now-outdated version of federal or state law in effect at the time the document was created. Because we have determined that the document provides valuable information not otherwise available, we continue to provide access to it through our website.