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Understanding the protections against disability-based discrimination

Written by Lusanda Molefe | Jan 6, 2025 11:42:07 PM

In 2024, the Department of Health and Human Services' Office for Civil Rights (HHS OCR) reinforced protections against disability-based discrimination through Section 504 of the Rehabilitation Act. This federal law ensures that individuals with disabilities have equal access to health and human service programs that receive federal funding. 

 

Legal framework

Section 504 of the Rehabilitation Act applies to healthcare organizations and programs receiving federal financial assistance. The law prohibits discrimination against individuals with disabilities in any program or activity that receives federal funding. Covered entities must ensure their services, programs, and activities are accessible to individuals with disabilities. This framework operates alongside other federal disability laws, such as the Americans with Disabilities Act (ADA), creating a comprehensive system of protections.

 

Specific protections

Healthcare organizations must implement various accessibility measures to comply with disability discrimination protections. 

  • Physical accessibility requirements include ensuring facilities are equipped with proper accommodations such as ramps, accessible medical equipment, and adequate space for mobility devices. 
  • Communication accessibility standards mandate the provision of auxiliary aids and services, including qualified interpreters, written materials in accessible formats, and assistive technologies. 
  • Program accessibility requires that all services and activities are available to individuals with disabilities.
  • Reasonable accommodation provisions ensure modifications to policies and procedures when necessary to provide equal access to healthcare services

 

Implementation requirements

Healthcare organizations must establish clear protocols to meet technical compliance standards for disability discrimination protections, which includes maintaining detailed documentation of accessibility features, accommodation requests, and modifications made to facilities or services. Staff training requirements ensure that healthcare workers understand their obligations under Section 504, including proper interaction with individuals with disabilities and handling of accommodation requests. Organizations must also implement reporting procedures to track compliance efforts and address any accessibility concerns promptly.

 

Compliance measures

Healthcare organizations must develop and maintain policies and procedures that outline their commitment to disability non-discrimination. These policies should detail specific protocols for handling accommodation requests, documenting accessibility measures, and addressing potential discrimination complaints. Regular assessments and evaluations help ensure ongoing compliance and identify areas for improvement. The HHS enforces these protections through investigating complaints, conducting compliance reviews, and implementing corrective actions when violations are found.

Related: The importance of policies and procedures in healthcare

What is the purpose of an OCR investigation?

 

FAQs

What constitutes "federal financial assistance" under Section 504?

This includes Medicare and Medicaid reimbursements, federal grants, and other forms of federal funding received by healthcare organizations.

 

How does Section 504 differ from the Americans with Disabilities Act (ADA)?

While both laws protect individuals with disabilities, Section 504 specifically applies to organizations receiving federal funding, whereas the ADA has broader application across public and private sectors.

 

What documentation should healthcare organizations maintain for Section 504 compliance?

Organizations should maintain records of accommodation requests, facility modifications, staff training, and accessibility assessments.