Much of the proposed changes seek to convert CMS existing and past sub-regulatory guidance and practices into regulation. By doing this, CMS provides a little more certainty to plans and providers that certain positions, approaches and policies of the agency will remain in force until a rule change is made through the prescribed process instead of simply a change in decision by the agency. It also seeks to clarify in regulation how certain issues have been addressed in practice but for which there is no clear law or regulation that supports the practice.
Disparate Impact is a legal doctrine under the Fair Housing Act which states that a policy may be considered discriminatory if it has a disproportionate “adverse impact” against any group based on race, national origin, color, religion, sex, familial status, or disability when there is no legitimate, non-discriminatory business need for the policy. LeadingAge is concerned that HUD’s proposal would make it nearly impossible for residents and applicants to prove that they have been discriminated against.
Here’s an overview of our work for you in December 2018.
LeadingAge was in full celebratory mode during May as we marked Older Americans Month, our annual opportunity to pause and reflect on the important contributions that older adults make to our nation. We launched a social media campaign to shine a spotlight on the month’s “Engage at Every Age” theme. We also honored older Americans by working throughout the month to support the work of LeadingAge members and to speak out for the people you serve.
