Evans backs GLAA on HMO regulations 08/06/99
GLAA writes DOH on proposed substance abuse program regs
Mr. Ronald E. Lewis
Addiction Prevention and Recovery Administration
D.C. Department of Health
1300 First Street, N.E., 3rd Floor
Washington, D.C. 20002
Dear Mr. Lewis:
I am writing with respect to the proposed rules on "Certification Standards for Substance Abuse Treatment Facilities and Programs," as published in the January 21 issue of the D.C. Register.
Section 2356 (page 399) is headed "Patient (Individual) Rights Standards." Subsection 2356.1 begins: "A substance abuse treatment facility or program shall protect the following rights and privileges of each patient, without limitation: (a) To be admitted and served regardless of race, sex, creed, religion, marital status, national origin, handicap or age."
This language is inadequate because it does not reflect the full range of protected classes enumerated under the D.C. Human Rights Act of 1977. The draft language is basically a list of categories protected by federal civil rights statutes (with one omission - color - and one redundancy - "creed" and "religion"), plus marital status. Omitted are the additional categories protected by the District's anti-discrimination laws: Sexual orientation, personal appearance, family responsibilities, matriculation, political affiliation, source of income, and place of residence or business.
A similar comprehensive list of protected categories should be inserted Into Section 2353, "Standards for Personnel Policies and Procedures" (page 394). The draft of that section currently refers to the need for substance abuse programs and facilities to include "an equal opportunity plan for hiring staff," but does not refer to the need for such programs and facilities to follow the employment protections laid down by the D.C. Human Rights Act.
Thank you for your consideration. We hope to hear from you soon.
Gay and Lesbian Activists Alliance of Washington, DC
cc: The Honorable Sandy Allen, Chairman, Committee on Human Services
The Honorable Kathy Patterson, Chairman, Committee on Government Operations
Carlene Cheatam, Office of the Mayor