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Empire Justice Comments on the Nondiscrimination in Health Programs and Activities Proposed Rules

November 17, 2015


We appreciate this opportunity to provide comments in response to the Notice of Proposed Rulemaking Regarding Nondiscrimination in Health Programs and Activities. Empire Justice Center is a statewide, multi-issue, multi-strategy public interest law firm focused on changing the “systems” within which poor and low-income families live in New York State. We believe in the critical importance of eliminating health disparities and ensuring that all people, including lesbian, gay, bisexual, transgender, queer, and intersex (LGBTQI) individuals and their families, do not face discriminatory barriers when seeking affordable health coverage and receive care that is also respectful and aware of the particular needs of this community.

We therefore strongly support the reforms introduced by the Affordable Care Act (ACA), particularly the application of essential nondiscrimination protections to the U.S. health system by ACA Section 1557. We applaud the work of the HHS Office for Civil Rights (OCR) to enforce these protections by actively investigating complaints and giving us the opportunity to provide comments that we hope will further strengthen the proposed rule.

We recognize that several other commenters have provided detailed responses to all of the proposed provisions we touch on below, and we do not wish to reiterate their thorough analyses superfluously. Instead, we endeavor to quickly state our support or lack thereof with regard to provisions that we expect will impact our client populations, and to offer more detail to expand upon the well-reasoned arguments of our fellow commenters as necessary.

CLICK HERE to read our comments in full.