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    November 13, 2023 

    U.S. Department of Health and Human Services
    Melanie Fontes Rainer
    Office for Civil Rights
    Hubert H. Humphrey Building, Rom 509F
    200 Independence Avenue SW
    Washington, DC 20201

    Re: Discrimination on the Basis of Disability in Health and Human Services Programs or Activities (RIN – 0945-AA15)

    Dear Director Fontes Rainer:

    On behalf of our member medical group practices, the Medical Group Management Association (MGMA) is pleased to provide the following comments in response to the Department of Health and Human Services (HHS) Office for Civil Rights’ (OCR’) proposed rulemaking on discrimination on the basis of disability in HHS programs or activities (proposed rule). MGMA is strongly supportive of ensuring persons with disabilities are not discriminated against and have equal access to care. We sincerely appreciate OCR’s attention to this topic as our members are dedicated to providing high-quality care to all patients.

    With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 group medical practices ranging from small private medical practices to large national health systems representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following policy recommendations.

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