The AAMC Oct. 26 submitted a letter to the Department of Health and Human Services (HHS) in response to its Notice of Proposed Rulemaking (NPRM) that proposed extending civil rights obligations to Health Insurance Marketplaces and all HHS health programs in order to advance health equity and minimize disparities in health care. The NPRM was published on Sept. 8, 2015.
In the letter, AAMC strongly supports HHS’ extension of nondiscrimination protections to transgendered populations and its strengthening of protections for individuals with disabilities and limited English proficiency. The AAMC also congratulates HHS on its application of these provisions to all health programs that receive any amount of federal assistance from any federal agency as such broad application will help ensure members of these vulnerable groups will likely be protected against discrimination at the majority of locations where they seek care or avail themselves of health promoting activities.
However, given the evidence of significant health inequities and biases experienced by lesbians, gays, bisexuals (LGB) and persons living with HIV/AIDS (PLWHA), the letter raises concern that the NPRM did not extend nondiscrimination protections to these groups. The association strongly urges HHS to broaden the definition of “sex” used to describe groups protected from sex discrimination to include LGB and PLWHA populations.