Comments on DOH Rulemaking Ignored
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Comments on DOH Rulemaking Ignored

Gay and Lesbian Activists Alliance of Washington, D.C.
P.O. Box 75265
Washington, D.C. 20013

August 5, 2004

Mr. Robert C. Bobb
City Administrator
1350 Pennsylvania Avenue, NW
Washington, D.C. 20004

Dear Mr. Bobb:

We were disappointed to read in the July 2, 2004 D.C. Register page 6629 that “no comments on the proposed rules were received” on the establishment of requirements for the Ticket to Work and Work Incentives Improvement Act (TWWIIA).

On March 17, I wrote to Robert Maruca, Senior Deputy Director of the Medical Assistance Administration as instructed in the March 2, 2004 D.C. Register regarding TWWIIA. That letter was copied via email to the Mayor; all D.C. Councilmembers; James Buford, then the Director of the Department of Health; Robert Spagnoletti, Attorney General; and Wanda Alston, Special Assistant to the Mayor for GLBT Affairs. A copy of the letter is on our website at

I took the trouble of sending copies because the Department of Health and other District agencies have too often ignored or disregarded comments by the public.

Specifically I asked, on behalf of GLAA, that domestic partners be considered in the eligibility of people in the program for financial resources limits. This is not a request for a handout, but rather a safeguard so that domestic partnerships may not be used as a way to hide financial resources to meet eligibility requirements. Under the District of Columbia Deed Recordation Tax Amendment Act of 2003—still in the 30-legislative day Congressional review period—domestic partners, like spouses, will be able to freely transfer assets between them without being subject to taxes. That is a very good law, but other laws and regulations much be changed to conform to this legal structure.

Under TWWIIA eligibility requirements, Section 4101.1(c) states:

Meet the Qualified Medical Beneficiary (QMB) resources limits set forth in 42 U.S.C. §§1396a(a)(10)(E)(i), 1396d(p)(1), 1396d(p)(3). The resource limits shall be $4000 for an individual and $6000 for his/her spouse;”

The second sentence should be replaced with “The resource limits shall be $4000 for an individual and $6000 for an individual and his/her spouse or domestic partner;”.

We ask that you intervene in this matter and change the TTWWIIA rules accordingly.

We also ask that you review the comment process so that citizen comments are not disregarded as a matter of course as is our repeated experience in the Department of Health. We trust that this will not be the case under the leadership of Dr. Gregg Pane.


Bob Summersgill

cc: Mayor Anthony Williams
All DC Councilmembers
Gregg A. Pane, Director of the Department of Health
Robert Spagnoletti, Attorney General
Wanda Alston, Special Assistant to the Mayor for GLBT Affairs
Robert Maruca, Senior Deputy Director, Medical Assistance Administration
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