On April 26, 2019, the Centers for Medicare & Medicaid Services (CMS) released Communications Accessibility for Individuals with Disabilities – Best Practices for Medicare Health and Part D Prescription Drug Programs. This document was submitted to the agency by IMPAQ International, LLC. The report focuses on auxiliary aids and services addressing communication-related accessibility needs, as those cover typical beneficiary interactions.
About a year and a half ago, some colleagues and I authored a white paper titled Accessible Communications: Standing Tall in Service. We realized the importance of this topic as the agency had released frequently-asked questions related to Section 504 of the Rehabilitation Act of 1973 (Section 504) and Section 1557 of the Affordable Care Act (Section 1557). I’m happy to report many of our recommendations and best practice concepts are also found in the IMPAQ piece, such as cultural competency training, leveraging qualified readers, tracking/maintaining beneficiary requests, analysis of complaint data, and auditing/monitoring of vendors. IMPAQ covers more in the arena of web accessibility, whereas I respectfully believe we covered more from a delegation oversight standpoint.
The reason we wrote this piece was because our number one priority was beneficiary access to care and service. I know for a fact the piece was not as popular as anything related to CMS program audits or marketing materials. Now that CMS has released these best practices, plans and delegates should sit up and take more notice of this topic. This could be a harbinger of things to come.