APIAHF Comment Letter to OCR Section 1557

APIAHF opposes the proposed changes to Section 1557 in the proposed rule that would limit application of the law to certain covered entities, eliminate protections for LGBTQ+ persons and persons needing reproductive health care, and roll back and eliminate certain language access protections. The NPRM runs counter to the explicit text of Section 1557 and its underlying purpose. Section 1557 prohibits discrimination on the basis of race, color, national origin, sex, age, and disability. As an organization that works to improve the health and wellbeing of minority and marginalized populations, we have direct experience advocating for the rights of persons protected by Section 1557 and an understanding of why the protections are required. Further, the protections of Section 1557 are not merely stand-alone, they address the intersection of the multiple protected classes covered. As such, an attack on the civil rights of one group in the NPRM is an attack on the civil rights of all. The focus of these comments will be on the fact that APIAHF opposes eliminating protections as proposed in the NPRM and urges the Department of Health and Human Services (HHS) to withdraw and not finalize this rule.