Disability Rights and Provider Obligations
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Defines provider obligations to prevent disability discrimination and ensure accessibility under Section 504, Section 1557, and ADA-related federal requirements; applies to Health Net National clinics and sites and their personnel. Covers posting notices, facility accessibility, accommodations, grievance procedures, and training requirements for staff.
No material clinical or coverage changes in this revision.
Operational Compliance Requirements
Operational compliance requirements
Required operational measures and procedures for sites to comply with federal disability nondiscrimination laws:
Notice posting
- Post a notice of consumer civil rights prominently in the clinic.
Facility accessibility and physical accommodations
Parking and approaches
- Provide parking spaces for persons with physical disabilities located in close proximity to accessible building entrances; each reserved space identified by a permanently affixed reflectorized sign or provide a reasonable alternative when the site lacks control over available accessible parking.
Ramps and landings
- Provide pedestrian ramps with a clear and level landing at the top and bottom of all ramps and on each side of an exit door (if multi-level) or a reasonable alternative.
Doorways and hardware
- Ensure exit and exam room doorway openings have a minimum clear opening of 32 inches with the door open at 90 degrees to allow passage of a person in a wheelchair or provide a reasonable alternative.
- Install door hardware operable with a single effort without requiring ability to grasp (e.g., latch or push-bars instead of doorknobs).
- Limit effort to operate interior doors to no more than 5 pounds of pressure.
Circulation and turning space
- Maintain clear floor space at least 30 in. x 48 in. for a stationary adult wheelchair in waiting and exam areas and a minimum clear turning area of 60 inches (diameter or square) or provide a reasonable alternative.
Vertical circulation and restrooms
- Provide accessible passenger elevators for multi-level accommodations or a reasonable alternative; ensure wheelchair-accessible restroom and handwashing facilities are available or provide a reasonable alternative.
Furniture and egress
- Ensure furniture and other items do not obstruct exit doorways or interfere with door swing pathways to maintain unobstructed egress.
Clinical equipment and signage
- Provide other accommodations or specialized equipment as needed (for example, height-adjustable exam tables, wheelchair-accessible weight scales, signage in raised letters and Braille) or reasonable alternatives.
Effective communication and interpreter services
- Provide effective communication including auxiliary aids and services; maintain 24-hour language and hearing-impaired interpreter services available to members via telephone/video services or on-site interpreters.
Grievance processing and compliance coordination
- For sites with 15 or more employees, implement a civil rights grievance procedure, designate an employee to coordinate compliance, and process all civil rights discrimination complaints following the site's Member Grievances/Complaints policy.
- Provide information to patients about filing complaints under Section 1557, including OCR website (www.hhs.gov/ocr), OCR toll-free numbers ((800) 368-1019; (800) 537-7697 TDD), and availability of OCR complaint forms in multiple languages; note that individuals may also file lawsuits under Section 1557.
Training
- Provide site personnel training on patient rights and provider obligations under the ADA, Section 504 of the Rehabilitation Act, and Section 1557 of the ACA, including physical access, reasonable accommodations, policy modifications, and effective communication in healthcare settings.
Facility Accessibility, Notices, and Grievance Handling
Post civil rights notice & maintain accessibility or reasonable alternatives
Post a notice of consumer civil rights in a prominent clinic location and ensure physical accessibility features or documented reasonable alternatives are available to make program services accessible to persons with disabilities.
- Post the notice in a prominent location in the clinic ([[chunk 4]]).
- Provide or have alternative plans for accessible parking, ramps with level landings, doorways with minimum 32-inch clear opening at 90°, hardware operable without grasping, interior door effort ≤ 5 lb, unobstructed egress, elevators where needed, accessible restrooms and handwashing facilities, clear wheelchair floor space 30 in. x 48 in. and 60-in turning area, and 24-hour language/hearing interpreter services ([[chunk 4]], [[chunk 5]]).
Handle civil rights grievances and designate compliance coordinator
Process civil rights discrimination complaints per the site's Member Grievances/Complaints policy and, for sites with 15 or more employees, designate an employee to coordinate compliance and follow a civil rights grievance procedure.
- Advise patients they may file a Section 1557 OCR complaint and provide OCR contact options (website and toll-free numbers) and available translated forms ([[chunk 6]]).
- For sites with 15+ employees, name the employee designated to coordinate compliance and ensure all civil rights complaints are processed following the site's Member Grievances/Complaints policy ([[chunk 6]]).
Key Definitions
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