CMS-10407 - Comment and Response document

60-Day Public Comment and Response for
Information Collection Requirements Contained in
Summary of Benefits and Coverage and Uniform Glossary
(CMS-10407/OMB Control Number 0938-1146)
Comment: This document fails to reflex the amendments to the civil rights act of 1964 which
included people with disabilities right to non discrimination.
One of the reasons for the affordable care act was to make sure people with per-existing
conditions could get health insurance. That being said. There should also be mention of the
Americans with disability Act and the requirement to provide alternative format when requested.
In the section of this document that deals with government provided health insurance policies
there should also include compliance with the civil right act of 1964 and the Americans with
disabilities.
Response: This ICR is a renewal of a pre-existing collection without amendment to the
underlying rules or requirements. As a result the ICR is not being amended or revised to add any
references to the Civil Rights Act of 1964, or its amendments, or references to the American’s
with Disabilities Act. We note that there is a Notice of Proposed Rulemaking (NPRM) with
proposed amendments to the Summary of Benefits and Coverage requirements. This NPRM is
open for public comment until March 2, 2015, and we would recommend submitting this
comment as part of that public record. In addition, there may be other requirements that apply to
group health plans and health insurance issuers in the group and individual markets, which
would require these entities to ensure publications, documents, and notices, potentially including
the Summary of Benefits and Coverage and the Uniform Glossary, are accessible and available
in alternative formats for people with disabilities. Because those requirements would exist under
other provisions, this ICR does not address such requirements or the burdens associated with
them.