As a rehabilitation provider, MossRehab is not content to simply comply with the Americans with Disabilities Act (ADA)—rather, our clinicians are actively involved in conceiving and implementing new ideas for increasing accessibility for our patients.

Critiquing Policy

In 2007, John Whyte, MD, PhD, director of Moss Rehabilitation Research Institute, was a member of a disability research committee formed by the Institute of Medicine. He and his colleagues authored The Future of Disability in America, a several hundred-page report that addressed, in part, shortcomings of the ADA in both content and enforcement. Among their findings, the committee concluded that ADA guidelines were too narrowly focused on the most common physical disabilities, usually only requiring, for example, wider doors or wheelchair-accessible bathrooms.

“But how comprehensible is your signage to a person with cognitive impairments? Does your staff know how to speak to a person who has language deficits? All these deeply important issues aren’t spelled out in the law,” Dr. Whyte said.

The committee also faulted enforcement of the ADA as overly “reactive,” as it often depended on a federal response to complaints brought forth by individuals. And while many of these complaints have ended in high-profile verdicts in favor of the plaintiff, the committee suggested ways the government could preemptively address accessibility issues before the public encounters them.

“Certainly the U.S. Department of Justice, which is responsible for enforcing Title III of the ADA, could disseminate guidelines to healthcare providers that describe compliance expectations,” Dr. Whyte explained. “Furthermore, we recommended that the Joint Commission ensure ADA compliance during its accreditation process.”

The committee also noted a lack of accessibility standards for medical equipment, including mammography machines, which require patients to stand for extended periods of time, and MRI and CT scanners, which force patients into a narrow tube. They recommended the government disseminate and enforce accessibility standards and provide technical assistance where needed.

Changing the Healthcare Environment

“The World Health Organization’s conceptual framework on disability makes three important distinctions,” Dr. Whyte said. “First, it states that impairments exist in a body part—a weak muscle or a poor memory. Second, it states that activities exist in a person—someone who can or cannot raise a spoon, or speak a sentence. But participation exists only at the person/environment interface. The ability of a person with a disability to participate in society depends as much on the environment as it does on the person, so we need to think about how we can make the environment more ‘disability friendly.’”

It is precisely this concept of adapting the environment to increase participation that has spurred MossRehab to enact an accessibility plan. Updated annually, this plan represents an ongoing process to identify and remove barriers to care, whether they are architectural, structural, environmental, attitudinal, financial, or communication-based.

Recent environmental changes include, for example, replacing standard doorknobs with lever handles in high traffic areas, and coating hallway floors with a textured material to increase traction for wheelchair users. MossRehab remove attitudinal barriers by requiring all clinicians and staff to undergo a disability etiquette program, where they encouraged to use “person first” language— “a person with brain injury” rather than “TBI patient”—and learn that assistive devices such as wheelchairs and walkers are considered “personal space” and should not be touched without permission. Staff and clinicians are also trained to watch for people who pause at signage, understanding this may be a result of cognitive impairment and could be a cue for offering assistance.

Mammography at MossRehab is performed with a special chair that can be mechanically raised and lowered. This feature facilitates transferring patients from their wheelchairs, and also alleviates the need to stand during the procedure. Likewise, a new multispecialty suite on the first floor of MossRehab was built with disability in mind, featuring wide doorways and mechanical examining tables.

MossRehab’s accessibility plan extends into legislative areas as well, ensuring financial and legal access to care. Ruth Lefton, MossRehab COO, and Alberto Esquenazi, MD, chairman of PM&R, both serve on the board of the FAIR Fund, which was established with major rehab payors across the country to fund a legal defense for patients who are denied insurance coverage for rehabilitation services. Kathy Gleason, program director for outpatient services, serves on a technical advisory committee at the Center for Medicare and Medicaid Services that is examining a new prospective payment system.