Preserving civil rights in the delivery of health care is an extremely critical issue, grounded and reinforced by a web of complex and intersecting laws health care providers receiving federal financial assistance (i.e., Medicare, Medicaid, etc.) are subject to.

These include:

• Title VI of the Civil Rights Act of 1964 (45 CFR Part 80)
  Prohibits discrimination based on race, color, religion, sex, or national origin.
• Age Discrimination Act of 1975 (45 CFR Part 91)
  Prohibits age-based discrimination in federally funded programs.
• Americans with Disabilities Act (ADA) Title III (28 CFR Part 36)
  Prohibits disability discrimination in public and private entities.

Building on these long-standing federal laws, are two healthcare-specific regulations that have recently undergone significant revisions:

• Section 504 of the Rehabilitation Act of 1973 (45 CFR Part 84) prohibits disability discrimination in federally funded healthcare programs.
• Section 1557 of the Affordable Care Act (45 CFR Part 92) prohibits discrimination based on race, color, national origin, sex, age, and disability—with expanded protections finalized in May 2024.

Compliance Deadlines

Section 1557 imposed staggered deadlines throughout 2024, with final training requirements due July 2025.

Rehab 504 also had phased in deadlines with most provisions effective in 2024, with digital accessibility and diagnostic equipment deadlines extending to 2026.

While some of the broader concepts introduced in the 2024 revisions to Section 1557 and Section 504 may continue to face legal and political challenges, one principle remains unwavering: the obligation to protect individuals with disabilities from discrimination in healthcare. These protections are deeply rooted in long-standing federal civil rights law and remain a cornerstone of equitable care in the United States.

What does this mean for you?

All of these interrelated, and somewhat redundant, regulatory requirements must be thoughtfully implemented and integrated into a cohesive set of civil rights policies and procedures. Crafting these documents is no small task—it demands a substantial investment of time and resources to thoroughly interpret complex regulations, operationalize each provision, and develop written policies that fully reflect the mandatory requirements.

Wild Consulting has done the labor-intensive heavy lifting for you and offers a comprehensive set of Civil Rights Compliance Policy and Procedure Templates. The ready-to-implement templates are a wealth of information you can easily utilize to inform the implementation of your Civil Rights Program, and include comprehensive policies and procedures and other documents to assist in the execution of this initiative. We have incorporated additional documents supplied by the federal government as a courtesy (free) so that all of the mandatory notices, forms, and charts are provided to you as a comprehensive package. The Civil Rights Compliance Policy and Procedure Templates include: