NCD Letter to the ACGME Regarding Disability Competency Training of Medical Professionals

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July 14, 2021

Thomas J. Nasca, MD, MACP
President and Chief Executive Officer
Accreditation Council on Graduate Medical Education
401 North Michigan Avenue, Suite 2000
Chicago, Illinois 60611

Dear Dr. Nasca:

By way of introduction, I am writing to you in my capacity as the Chairman of the National Council on Disability (NCD). We are an independent federal agency charged with advising the President, his administration, Congress, and federal agencies on matters of disability law and policy. The purpose of this letter is to request a meeting with you to discuss how the Accreditation Council for Graduate Medical Education (ACGME) can play a vital and pivotal role in addressing a national problem that affects the overall safety and quality of care provided to over 64 million people with disabilities.

For a number of years, NCD has embarked on an appraisal of healthcare access, treatment, and outcomes in patients with disabilities. Our efforts have been heightened over the last 14+ months due to the pandemic and the detrimental disproportionate effect it has on the disability community. There is robust literature from the United States Surgeon General, the Center for Disease Control and Prevention, the National Institutes of Health, the National Academies of Science, Engineering and Medicine, and leading healthcare institutions and researchers, that acknowledges and confirms the statistically significant sub-optimal treatment for this vulnerable patient population in the healthcare sector. While there is a myriad of contributing factors involved in the health disparities in patients with disabilities (e.g., access, stigma, reimbursement, transportation, economics, and environment), one of the main identified factors is the lack of physician training in the assessment, management, and treatment of patients with disabilities.[1] This lack of training is a noted deficit in both graduate medical education as well as post-graduate clinical training in residency and fellowship programs.

Medical schools do not provide meaningful education in treating patients with disabilities and thus graduates enter residency and fellowship programs with little or no skills, knowledge, comfort, confidence, or awareness in their proper treatment. These deficits are reflected in adverse clinical outcomes. ACGME accredited residency and fellowship programs - all 12,000, at approximately 865 sponsoring institutions – continue this training void and witness clinicians transitioning into practice without preparation to provide culturally competent and appropriate care to millions of individuals with disabilities. In addition to primary care, the obvious negative consequences are observed daily in every specialty and sub-specialty.

While disability cultural competency training for medical professionals was needed prior to the pandemic, the treatment of persons with disabilities in healthcare settings during the pandemic has highlighted the dire need for medical professionals to receive disability cultural competency as many hospitals and healthcare providers deprioritized, and in certain instances categorically excluded persons with disabilities from receiving treatment for the COVID–19 virus. This is a problem that can no longer be ignored and must be remedied. ACGME can play a vital role in its solution.

NCD recently worked with the American Dental Association in revising its Code of Professional Conduct[2] to state that patients cannot be denied care because of their disability (a standard adopted by several states as state law of professional conduct). NCD also worked with the Council on Dental Accreditation (CODA) in revising its standards, which now mandate that dental students must be trained in the assessment, management and treatment of patients with “[sic]special needs” (“special needs” is described by CODA’s published intent as “those patients whose medical, physical, psychological, cognitive or social situations make it necessary to consider a wide range of assessment and care options…these individuals include, but are not limited to, people with developmental disabilities, cognitive impairment, complex medical problems, significant physical limitations, and the vulnerable elderly”).[3] In much the same way that those requirements were developed for compliance with Section 504 of the Rehabilitation Act of 1973[4] and the Americans with Disabilities Act,[5] it is vital that disability cultural competency training be part of medical education and training.

In this regard, NCD urges ACGME to require all of its accredited residency and fellowship programs adopt and implement disability cultural competency training to ensure that physicians are prepared to meet the health needs of people with disabilities. We recommend that such training incorporate the Core Competencies on Disability for Health Care Education drafted by the Alliance for Disability in Health Care Education. Those core competencies present standards on social, environmental, and physical aspects of disability to inform future health professionals on how to provide effective, interprofessional team-based health care. Moreover, it is imperative that people with disabilities are involved in the development of that training.

We would like to meet with you and discuss this recommendation and to collaboratively discuss other strategies to achieve health equity, improved safety, and enhanced quality of care for the growing number of Americans with disabilities across their lifespan. Addressing this long-standing void in medical education and residency training is consistent with ACGME’s mission “to improve health care and population health by assessing and enhancing the quality of resident and fellow physicians' education through advancements in accreditation and education.” Doing so is also in furtherance of your recent call for physicians and educators to move society towards dignity, healing and justice for all people.  Respectfully, now is truly your moment.

I look forward to learning of your thoughts regarding this request. As a matter of courtesy, Amged M. Soliman, NCD Attorney Advisor, will call your office on July 12, 2021, to coordinate a date and time for an initial discussion. If you have any questions or desire to reach me in advance of that call, you can reach me via email at agallegos@ncd.gov. Mr. Soliman can be reached at asoliman@ncd.gov or 202-731-5910.

Respectfully,

Andrés J. Gallegos
Chairman

 

Cc:     Chair, Dr. Karen J. Nichols
Chief of Staff & Chief Education Officer, Dr. Timothy P. Brigham
Accreditation Council on Graduate Medical Education
401 North Michigan Avenue, Suite 2000
Chicago, Illinois 60611

 

 




[1] Also see NCD’s most recent report, Enforceable Accessible Medical Equipment Standards: A Necessary Means to Address the Health Care Needs of People with Mobility Disabilities (2021), which describes the considerable body of research on the health disparities of people with disabilities and focuses on the role of inaccessible medical diagnostic equipment in health care settings as both a major barrier to equitable health care and a perpetuator of health disparities for people with mobility disabilities. In this report, NCD recommends that ACGME require all federally funded medical residency programs to include disability competency training, which includes the importance of accessible medical diagnostic equipment to help ensure equitable access to health care and reduce health care disparities.

[3] The Commission on Dental Accreditation. “Accreditation Standards

For Dental Education Programs.” https://www.ada.org/~/media/CODA/Files/predoc_standards.pdf?la=en. (Accessed July 1, 2021.)

[4]  29 U.S.C. § 794.

[5]  42 U.S.C. § 12101.