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AFBAmerican Foundation®
for the Blind

Expanding possibilities for people with vision loss

Vision Loss Community Delivers Powerful Health Care Reform Message to Law Makers

For further information: Mark Richert, Director, Public Policy,
American Foundation for the Blind
202-822-0833 mrichert@afb.net

We, the more than 100 undersigned international, national, and community-based organizations representing, serving, and advocating for the more than 20 million Americans of all ages experiencing significant vision loss, urge you to exercise your leadership to ensure that any comprehensive health reform legislation enacted by the 111th Congress adequately addresses the needs and rights of individuals living with vision loss. Specifically, we call upon Congress to send to President Obama legislation that, at a minimum

  • ensures that individuals with vision loss and other disabilities can properly identify and take medications by mandating appropriate labeling standards and methods for providing nonvisual and enhanced visual access to drug container labeling and related information;

  • establishes clear Medicare (or other national minimum benefit plan) coverage for, and fosters broader private plan availability of, low vision devices and other medically necessary assistive technologies; and

  • allows orientation and mobility specialists, vision rehabilitation therapists, and low vision therapists to be full participants in the professional team providing specialized services to people with vision loss by establishing unambiguous Medicare (or other national minimum benefit plan) reimbursement for the services such professionals offer.

Congress is currently weighing a variety of health care policy options that have the potential to fundamentally transform the scope and delivery of health care to all Americans. While many of these policy options could be of significant benefit to Americans with vision loss, we are concerned that proper attention is not being given in the policy debate to several basic health care needs experienced by people who are blind or visually impaired. We therefore ask for your help to craft and enact policy solutions as part of health care reform to address these unmet needs.

Drug Label Information

Current Law: No state in the union clearly requires labeling of prescription or other medications to be accessible to individuals with vision loss through minimum large print font size, audible labeling technologies, tactile markings or braille, or other methods calculated to provide alternatives to visual use of medication labeling and related information. Moreover, current federal law places no meaningful requirements on such labeling to ensure nonvisual and enhanced visual access. Additionally, while retail pharmacies can be held accountable for providing some degree of access to label information under the Americans with Disabilities Act, the ADA neither provides standards for pharmacies to follow nor establishes a consistent national policy ensuring that customers will, upon request, be provided the nonvisual or enhanced visual means of their choice to use drug labeling safely and independently. The failure to make medication labeling accessible to people with vision loss has been shown to lead to significant health risks (see e.g., consumer survey conducted by the American Foundation for the Blind at www.afb.org/labels).

Proposed Policy: Congress should enact legislation requiring retail pharmacies to offer, upon the request of a customer, nonvisual or enhanced visual means for using medication labeling and related print information safely and independently. The means to accomplish label accessibility must be the means of the customer's choice and conform to national minimum standards to ensure consistency, reliability, and customer privacy.

Low Vision Devices and Other Medically Necessary Assistive Technology

Current Law: Very few private health plans offer customers access to low vision devices or other assistive technologies that maximize remaining usable vision or otherwise provide nonvisual access to information and the environment. Moreover, the Centers for Medicare and Medicaid Services (CMS) refuse Medicare coverage of any device that employs one or more lenses regardless of a device's other technological features simply on the grounds that devices using lenses fall within the long-standing statutory bar on coverage for eye glasses. Other categories of assistive technology are routinely denied coverage on the grounds that they are convenience items, are not primarily for use in the home, or on other erroneous bases. People with vision loss can use low vision devices and other assistive technologies to manage their health care needs, properly identify medications, maintain proper diet, and ensure safe mobility at home and in community. Along with appropriate rehabilitation services, low vision devices and other assistive technologies prevent injury and the acquiring of additional disabling conditions.

Proposed Policy: Congress must overturn the CMS regulation barring coverage for low vision devices and establish clear criteria for their provision. Such criteria should acknowledge other distinctive features employed by the most valuable low vision devices, other than their mere use of a lens, such as a device's integration of a light source, use of electrical power, or other distinctive features. In addition, Congress must establish clear parameters for CMS to follow to provide Medicare beneficiaries with vision loss access to assistive technologies meeting their unique needs.

Vision Rehabilitation Services

Current Law: Medicare currently pays for some forms of vision rehabilitation services provided under the direct supervision of a physician and offered by an array of state licensed personnel. However, orientation and mobility specialists, vision rehabilitation therapists, and low vision therapists, professionals who are explicitly trained to provide such vision rehabilitation services, are not among the professional disciplines recognized for purposes of Medicare reimbursement. This means that, while the services offered by other professionals--such as occupational and physical therapists--are services provided by personnel who are regularly part of the team of providers offering some limited form of vision rehabilitation addressing, for example, a beneficiary's needs for daily living skills training or other related services, the professional team is incomplete. As a result, beneficiaries are not ensured access to the full range of quality services, such as orientation and mobility, provided by the best qualified professional disciplines. Moreover, since the limited vision rehabilitation-like services that CMS will pay for must be provided under strict physician supervision, these services, which are most relevant when offered in a beneficiary's home or in community, are diminished in effectiveness. Finally, a Medicare demonstration project currently being undertaken to assess vision rehabilitation reimbursement has such significant design and administrative flaws that Congress should not wait for the project's conclusions or have confidence in their validity.

Proposed Policy: Congress must establish unambiguous coverage for the services offered to Medicare beneficiaries by orientation and mobility specialists, vision rehabilitation therapists, and low vision therapists to allow the most qualified and complete team of professional service providers to meet the unique needs of individuals with vision loss. Such services should be allowed to be provided in a beneficiary's home and community to maximize their effectiveness.

Thank you for your thoughtful consideration and for your advocacy on behalf of Americans living with vision loss. We look forward to working closely with you as health reform moves forward.

Respectfully,

Academy for Certification of Vision Rehabilitation and Education Professionals, National Headquarters, Tucson, AZ
Accessible Design for the Blind, Asheville, NC
Alaska Center for the Blind & Visually Impaired, Anchorage, AK
Alphapointe Association for the Blind, Kansas City, MO
American Association of the Deaf-Blind, National Headquarters, Silver Spring, MD
American Council of the Blind, National Headquarters, Washington, DC
American Council of the Blind of Maine, Clinton, ME
American Foundation for the Blind, National Headquarters, New York, NY
American Society of Consultant Pharmacists, National Headquarters, Alexandria, VA
American Society on Aging, National Headquarters, San Francisco, CA
Associated Services for the Blind and Visually Impaired, Philadelphia, PA
Associates for World Action in Rehabilitation & Education, Mohegan Lake, NY
Association for Education and Rehabilitation of the Blind and Visually Impaired, National Headquarters, Alexandria, VA
Association for Education and Rehabilitation of the Blind and Visually Impaired of Ohio, Columbus, Ohio
Association for Gerontology and Human Development in Historically Black Colleges and Universities, National Headquarters, Atlanta, GA
Association for the Blind & Visually Impaired, Grand Rapids, MI
Association for Vision Rehabilitation and Employment, Binghamton, NY
Association of Blind Citizens, Holbrook, MA
Aurora of Central New York, Syracuse, NY
Badger Association of the Blind and Visually Impaired, Milwaukee, WI
Bay Area Digital, San Francisco, CA
Bay State Council of the Blind, Watertown, MA
Blind Childrens Center, Los Angeles, CA
Blinded Veterans Association, National Headquarters, Washington, DC
Blind Services Planning Council, Chicago, IL
Braille Institute of America, Los Angeles, CA
Cabell-Wayne Association of the Blind, Huntington WV
California Council of the Blind, Sacramento, CA
Carroll Center for the Blind, Newton, MA
Catholic Charities Maine, Portland, ME
Center for Deaf-Blind Persons, Milwaukee, WI
Center for the Partially Sighted, Los Angeles, CA
Center for the Visually Impaired, Atlanta, GA
Central Association for the Blind and Visually Impaired, Utica, NY
Cincinnati Association for the Blind and Visually Impaired, Cincinnati OH
Cleveland Sight Center, Cleveland, OH
Clovernook Center for the Blind and Visually Impaired, Cincinnati, OH
Community Services for the Blind and Partially Sighted, Seattle, WA
Council of Citizens with Low Vision International, International Headquarters, Arlington, VA
Delta Gamma Center for Children with Visual Impairments, Richmond Heights, MO
Earle Baum Center of the Blind, Santa Rosa, CA
Florida Association of Agencies Serving the Blind, Tallahassee, FL
Florida Lions Conklin Center for the Blind, Daytona Beach, FL
Foundation for Blind Children, Phoenix, AZ
Georgia Council of the Blind, Athens, GA
GettingHired.com, Bedminster, NJ
Greater New York Council of the Blind, New York, NY
Guide Dogs for the Blind, San Rafael, CA
Guiding Eyes for the Blind, Yorktown Heights, NY
Hadley School for the Blind, Winnetka, IL
Hampton Roads Blinded Veterans, Hampton, VA
Hatlen Center for the Blind, San Pablo, CA
Hawaii Center for Independent Living, Hilo, HI
Helen Keller National Center, National Headquarters, Sands Point, NY
Helen Keller Services for the Blind, Brooklyn NY
Hollinger Consulting, St. Charles, MO
HumanWare, U.S. Headquarters, Concord, CA
Illinois Association for Parents of Children with Visual Impairments, Naperville, IL
Illinois Council of the Blind, Springfield, IL
Independence for the Blind of West Florida, Pensacola, FL
International Association of Audio Information Services, Detroit, MI
Iowa Braille and Sight Saving School, Vinton, IA
Iowa Statewide System for Vision Services, Vinton IA
Iris Network, Portland, ME
Junior Blind of America, Los Angeles, CA
Leader Dogs for the Blind, Rochester, MI
Lighthouse Central Florida, Orlando, FL
LightHouse for the Blind and Visually Impaired, San Francisco, CA
Lighthouse for the Blind of Houston, Houston, TX
Lighthouse for the Blind, Seattle, WA
Lighthouse for the Visually Impaired, Brooksville, FL
Lighthouse International, New York, NY
Lighthouse of Broward, Fort Lauderdale, FL
Lighthouse of Pinellas, Largo, FL
Lions Clubs International, International Headquarters, Oak Brook, IL
Louisiana School for the Visually Impaired, Baton Rouge, LA
MAB Community Services, Worcester, MA
MaryAnn Keverline Walls Low Vision Center, Southern California College of Optometry, Fullerton, CA
Metrolina Association for the Blind, Charlotte, NC
Miami Lighthouse for the Blind and Visually Impaired, Miami, FL
Michigan Statewide Independent Living Council, Lansing, MI
Montgomery County Association for the Blind, North Wales PA
National Accreditation Council for Agencies Serving People with Blindness or Visual Impairment, National Headquarters, Middleburg Hts., OH
National Association for Parents of Children with Visual Impairments, National HQ, Watertown MA
National Association of State Long-Term Care Ombudsman Programs, National Headquarters, Midland, MI
National Coalition on Deaf-Blindness, National Headquarters, Watertown, MA
National Federation of the Blind of Massachusetts, Holbrook, MA
National Industries for the Blind, National Headquarters, Alexandria, VA
National Senior Citizens Law Center, Oakland, CA
New Jersey Foundation for the Blind, Denville, NJ
North Dakota Vision Services/School for the Blind, Grand Forks, ND
Northwest Suburban Special Education Organization, Mt. Prospect, IL
Oklahoma League for the Blind, Oklahoma City, OK
Peninsula Rehabilitation Services, Quilcene, WA
Pennsylvania Council of the Blind, Harrisburg, PA
Perkins School for the Blind, Watertown, MA
Raleigh Lions Clinic for the Blind, Raleigh, NC
San Antonio Lighthouse for the Blind, San Antonio, TX
Susquehanna Foundation for the Blind, Lancaster, PA
The New York Institute for Special Education, Bronx, NY
The Seeing Eye, Morristown, NJ
Virginia School for the Deaf and Blind, Staunton, VA
Vision & Vocational Services, Columbus OH
Vision Consultants of West Michigan, Kalamazoo, MI
Vision Loss Resources, Minneapolis, MN
VisionServe Alliance, National Headquarters, St. Louis, MO
VISIONS/Services for the Blind and Visually Impaired, New York, NY
Vista Center for the Blind & Visually Impaired, Palo Alto, CA
Visually Impaired Persons of Southwest Florida, North Fort Myers, FL
Westchester Council of the Blind, Mt. Kisco, NY

Prepared June 4, 2009

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