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    August 13, 2019  

    Roger Severino, Director
    Office for Civil Rights Department of Health and Human Services
    Hubert H. Humphrey Building, Room 509F
    200 Independence Avenue SW
    Washington, D.C. 20201 
    RE: Nondiscrimination in Health and Health Education Programs or Activities Proposed Rule 
    Dear Director Severino: 
    The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the June 14, 2019 proposed rule amending regulations under Section 1557 of the Affordable Care Act (ACA).  MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 45,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 practices of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.

    On May 18, 2016, the Office for Civil Rights (OCR) under the Department of Health and Human Services (HHS) finalized regulations implementing Section 1557 at 45 C.F.R. Part 92 (2016 regulations) and on June 14, 2019 proposed to amend certain provisions of those regulations. While some of the most significant proposals in the June 14, 2019 rule relate to discrimination on the basis of sex, certain provisions of OCR’s proposals impact the implementation and enforcement of Section 1557’s prohibition of discrimination on the basis of disability and nationality.  


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