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NCD Letter to AHRQ on ADME Report Monday, August  2, 2021
 
 David Meyers, M.D.
Director
Agency for Healthcare Research and Quality
5600 Fishers Lane
Rockville, MD 20857 Arlene S. Bierman, M.D.
Director
Center for Evidence and Practice Improvement
Agency for Healthcare Research and Quality
5600 Fishers Lane
Rockville, MD 20857 Dear Dr. Meyers and Dr. Bierman: I am writing to you in my capacity as the Chairman of the National Council on Disability (NCD) to provide you with findings from our June 2021 report on accessible medical diagnostic equipment and to present a recommendation to the Agency for Healthcare Research and Quality (AHRQ) based on our findings. NCD is an independent federal agency charged with advising the President, his administration, Congress, and federal agencies on matters of disability law and policy. For a number of years, NCD has embarked on an appraisal of healthcare access, treatment, and outcomes for patients with disabilities. Framed in the context of reducing healthcare disparities and achieving health equity for patients with disabilities, NCD’s report, *Enforceable Accessible Medical Equipment Standards: A Necessary Means to Address the Health Care Needs of People with Mobility Disabilities*,[[1]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftn1) provides a review of decades of literature that acknowledges and confirms the statistically significant sub-optimal treatment of people with disabilities in the receipt of healthcare from sources including the U.S. Surgeon General, the Center for Disease Control and Prevention, the National Institutes of Health, the National Academies of Science, Engineering and Medicine, and leading healthcare institutions and researchers, including AHRQ.[[2]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftn2) While several factors contribute to the well documented health disparities experienced by patients with disabilities (*i.e.,* access, stigma, reimbursement, transportation, economics, and environment), our report focuses on the widespread lack of accessible medical diagnostic equipment (accessible MDE) in healthcare settings that creates a physical access barrier to over 20 million individuals with mobility limitations in the U.S. This number is expected to grow given population health trends, such as increasing rates of chronic medical conditions, obesity, and the aging population. Among NCD’s key findings: Adults with disabilities: are 12.7 times more likely to report poor overall health status compared to adults without disabilities; have obesity rates for adults and youth with disabilities are 58 and 38 percent, respectively, higher than those of their nondisabled peers; less likely than people without disabilities to have had an annual dental visit; less likely than people without disabilities to have had a mammogram in the last two years; less likely than people without disabilities to have had a Pap test in the last three years; and significantly less likely to be weighed as part of routine care.
  Adults with mobility impairments are at higher risk of foregoing or delaying necessary healthcare and having unmet medical, dental, and prescription needs compared to adults without disabilities.
  Lack of timely access to primary and preventive care can result in the development of chronic and secondary conditions as well as the exacerbation of the original disabling condition itself, resulting in poorer health outcomes.
  The lack of accessible MDE remains widespread despite federal laws which require healthcare providers to ensure full and equal access to their healthcare services and facilities.
  Inaccessible MDE is a major barrier to receiving necessary healthcare, compromises quality of care, and has resulted in delayed care, incomplete care, and missed diagnoses, and perpetuates the significant health disparities of people with mobility impairments.
  Without widespread availability of height adjustable examination tables, accessible mammography equipment, accessible weight scales and lift equipment to facilitate transfers, among other accessible medical and diagnostic equipment, people with mobility impairments will remain less likely to receive recommended preventive healthcare services—like cervical cancer screening; colorectal cancer screening; obesity screening; and breast cancer screening. Bolstering our report findings and the research described therein, is a newly released national survey that explored the extent to which outpatient physicians nationwide use accessible weight scales and exam tables/chair when caring for patients with significant mobility limitations.[[3]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftn3) A survey was developed and administered to 714 physicians in family medicine, general internal medicine, rheumatology, neurology, ophthalmology, orthopedic surgery, and obstetrics-gynecology (OB/GYN). The first 6 specialties were chosen because they see large numbers of patients with disabilities, and OB/GYN was chosen because many women see gynecologists for routine care and prior research (as discussed in NCD’s report) identified high rates of inaccessible equipment in OB/GYN offices. The survey revealed that only 22.6% used accessible weight scales, and only 40.3% used accessible exam tables/chairs.[[4]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftn4) We have been talking about healthcare disparities for decades, but despite the clear need shown in study after study, the use of inaccessible equipment used for basic healthcare remains the norm. Our report recognizes AHRQ’s key role in producing evidence and creating materials to teach healthcare systems and professionals to put research into practice. Today, NCD urges you to act on behalf of over 20 million people with mobility impairments who need improved access to a physician’s care. NCD recommends that AHRQ fund a broad-based, national biannual survey on the availability and use of accessible MDE. This survey could build on the survey described above, or a survey highlighted in our report, used to assess the availability of accessible MDE in the offices of California Medicaid providers. At minimum, it should include all Medicaid providers as they are readily identifiable and must comply with the strictest standards under federal disability nondiscrimination law, *e.g.,* Section 504 of the Rehabilitation Act and implementing regulations.[[5]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftn5) We believe such surveys would increase the ability of healthcare providers to accommodate the needs of people with disabilities by increasing opportunities for preventive care - resulting in improved health outcomes and reduced health disparities. Furthermore, it would advance AHRQ’s mission to produce evidence to make healthcare safer, higher quality, more accessible and equitable. We would welcome a meeting with you to discuss this letter in the near future. As a matter of courtesy, Ana Torres-Davis, Senior Attorney Advisor, who oversaw the development of our report referenced here, will reach out to your office on August 16, 2021, to coordinate a date and time for a potential meeting between us to discuss the issues addressed in this letter unless we hear from you before then. If you have any questions, Ms. Torres-Davis can be reached at atorresdavis@ncd.gov. You may also reach me directly at *agallegos@ncd.gov*. Respectfully, Andrés J. Gallegos
Chairman   [[1]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftnref1) National Council on Disability (June 2021). Available online at https://ncd.gov/publications/2021/enforceable-accessible-medical-equipment-standards. [[2]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftnref2) AHRQ’s 2009 and 2010 National Healthcare Disparities Reports examined disparities in health and dental care for people with disabilities. [[3]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftnref3) Lisa I. Iezzoni MD, MSc , Sowmya R. Rao PhD , Julie Ressalam MPH, Dragana Bolcic-Jankovic PhD , Karen Donelan ScD, EdM , Nicole Agaronnik, Tara Lagu MD, MPH, Eric G. Campbell PhD, Use of Accessible Weight Scales and Examination Tables/Chairs for Patients with Significant Mobility Limitations by Physicians Nationwide, *The Joint Commission Journal on Quality and Patient Safety* (2021), doi: https://doi.org/10.1016/j.jcjq.2021.06.005 [[4]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftnref4) Id. [[5]](https://ncd.gov/publications/2021/ncd-letter-ahrq-adme-report#_ftnref5) 29 U.S.C. 794; 45 C.F.R. Part 84.


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