October 15, 2019

October 15, 2019

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October 14, 2019

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ACA Section 1557: Are You Prepared to Meet the October 16 Deadlines?

In less than three weeks, health care providers covered by the Affordable Care Act must meet various posting obligations required by the recently issued Section 1557 regulations. We have written extensively about the Final Rule, including the expansive nondiscrimination standards and the upcoming October 16 deadlines. While we encourage you to review these publications for more detail, covered entities urgently need to prepare by October 16, 2016, nondiscrimination notices and taglines to be posted (1) in significant publications or communications; (2) in conspicuous physical locations where they interact with the public; and (3) in a conspicuous location on their website.

Nondiscrimination notices must include, among other things, a statement of nondiscrimination, the availability of interpretive services for patients with limited English proficiency (LEP), the availability of auxiliary aids and services for individuals with disabilities, and the availability of a grievance procedure for discrimination complaints. In small-sized publications, such as postcards and pamphlets, the notice may be shortened to include only the nondiscrimination policy.

Taglines, which are statements of the availability of language assistance services, must be posted in the same locations. In large-format publications, taglines must be posted in at least the top 15 languages for the relevant state.  In small-sized publications, taglines must be posted in the top two languages.

With the October 16th deadline quickly approaching, in addition to complying with Section 1557’s notice requirements, covered entities should develop a plan to ensure they are able to provide the services and procedures promised in the required notices.

©2019 Epstein Becker & Green, P.C. All rights reserved.

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About this Author

Frank Morris, Health Care Attorney, Epstein Becker Law Firm
Member of the Firm

FRANK C. MORRIS, JR., is a Member of the Firm in the Litigation and Employee Benefits practices, heads the Labor and Employment practice in the Washington, DC, office, and co-chairs the firm's ADA and Public Accommodations Group.

Mr. Morris' experience includes:

  • Advising clients on and litigating employment, labor, disabilities, non-compete, confidentiality, benefits, information access and privacy, wage and hour, and general litigation matters in state and federal courts and administrative agencies...

202-861-1880
Nathaniel M. Glasser, Epstein Becker, Labor, Employment Attorney, Publishing
Member

NATHANIEL M. GLASSER is a Member of the Firm in the Labor and Employment practice, in the Washington, DC, office of Epstein Becker Green. His practice focuses on the representation of leading companies and firms, including publishing and media companies, financial services institutions, and law firms, in all areas of labor and employment relations.

Mr. Glasser’s experience includes:

  • Defending clients in employment litigation, from single-plaintiff to class action disputes, brought in federal court, state court, and arbitration tribunals involving claims of unlawful discrimination, harassment, retaliation, breach of contract, defamation, alleged violation of the FLSA and state wage and hour laws, and whistleblowing

  • Representing clients facing charges at the U.S. Equal Employment Opportunity Commission, the U.S. Department of Labor, the District of Columbia Commission on Human Rights, the New York State Division of Human Rights, the New York City Commission on Human Rights, and other administrative agencies at the federal, state, and local levels

202-861-1863
Michael D. Thompson, newark, epstein becker, labor, litigation, employment
Member

Mr. Thompson's experience includes:

  • Representing employers before state and federal courts in litigation concerning federal and states discrimination laws, retaliation claims, and other employment matters

  • Litigating wage-and-hour collective actions and other class actions

  • Overseeing the development of comprehensive compliance programs and providing advice on the development and implementation of business policies and practices that foster compliance...

973-639-8282