# Boston Center for ndependent Living, Inc.

September 27, 2013 Mr. Rex Pace Ms. Earlene Sesker U.S. Access Board pace@Access
- Board.gov sesker@Access
- Board.gov **Re** : Comments on Exam Tables and Chair s Subcommittee Report Dear Mr. Pace , Ms. Sesker, and Members of the U.S. Access Board: The following comments are provided regarding the Access Board’s Exam Tables and Chairs Subcommittee Report. The Boston Center for Independent Living (BCIL) was found ed in 1974 as the nation’s second independent living center, and annuall y provides services to over 4,000 people with disabilities in Greater Boston. Itis a civil rights organization led by people with disabilities, advocating to eliminate discrimination, isolation and segregation b y providing advocacy, information and referral, peer support, skills training and personal care attendant (PCA) services in order to enhance the independence of people with disabilities. BCIL specifically a dvocates for improved access to public transportation, employment, housing, government services, public accommodations, and health care. BCIL maintains an active membership, numbering over 500 people with disabilities. As a member
- led organization, with scores who have fac ed repeated discrimination in obtaining health care, BCIL has prioritized efforts to support equal access to health care. W e have reached binding agreements with Massachusetts General Hospital and Brigham’s and Women’s Hospital, with a comparable one pendi ng with the Boston Medical Center, to improve access to care and services for people with disabilities and ensure compliance with the Americans with Disabilities Act. In this work we have connected with many persons with significant ph ys ical disabilities who have encountered major barriers to care and services in a medical setting, and these persons’ experiences underlay the advocacy

efforts that produced these agreements. One of the most frequent concerns of these individuals was their inability to rece ive proper medical exams because they could not get on an examination table or because they were transferred to a table in an unsafe way . The consequence of examinations in wheelchairs was often second
- rate care, undoubtedly resulting in poorer health outc omes in certain instances. In addition, even whe n transfer solutions were offered by medical practitioners, those responses often included dangerous and undignified lifting by personnel not trained to carry out the task. BCIL members have been unable to have gy necological exams, or have needed to be lifted b y a husband onto tables, or were lifted, while undressed, by male orderlies or even untrained securit y 60 Temple Place, 5 th Floor , Boston, MA 02111
- 1324 617 338
- 6665 (Voice) 617 338

- 6662 (TTY) 617 338

- 6661 (Fax)

866 338
- 8085 (Toll Free) in fo@bostoncil.org (e

- mail) www.bostoncil.org (website)guards. As a result, the barrier of inaccessible exam tables has produced another notable

consequenc e: it discourages individuals from actually seeking needed care. A close associate has endured a ye ar of chemotherap y and surgery for advanced cancer that may have been detected had she not avoided a precautionary exam in part because of the anticipated humiliation of having to explain

—ye t again

— that as a paraplegic she could not stand to access her examination procedure. Any thing that inhibits proper transfers for people with disabilities, and not necessarily just those using wheelchairs, restricts care

— which is both a profound civil rights violation and a major impediment to quality delivery of health care. A history

of neglect by medical facilities regarding the simple aim of access to an exam table has harmed countless people with disabilities. A failure to mandate the best
- possible access, something that would benefit people of short stature, including frail elders, little people, and children with disabilities, is not acceptable. The most expansive access possible is needed . F or way too long people w ith disabilities have faced unequal access because of calculations made in the name of expediency and short
- term cost savings. The data provided to the Examination Tables and Chairs Subcommittee and articulated by medical practitioners in meetings and reported in the Examination Tables and Chairs Subcommittee report speaks to a low
- height requirement of 17 inches for exam tables. BCIL strongl y supports this, especiall y as we recall the late Frances Deloatch, a BCIL member who was involved in our advocacy work with Brigham and Women’s Hospital. For her, a two
- inch lower exam table may

have been critical. Frances had osteogensis imperfecta and was onl y three feet three inches tall. She once said that if her primary care phy sician had an exam table that lowe red, she could transfer to it independentl y from her wheelchair. However, because of her stature, Frances had a child
- sized wheelchair, and there is a very good chance that 19 inches would have been too high for her to self
- transfer. We cannot ignore individuals like Frances. A 17
- inch height would provide greater accessibility

and enhance the safet y of transfers for small individuals. BCIL encourages you to develop the standard that will guarantee access to the greatest number of persons with disabil ities possible. Thank you for considering m y comments on behalf of our members and for the board’s work to achieve equal access.
Sincerel y, Bill Henning B ill H enning Executive D irector