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2011 DISABILITY and HEALTH PARTNERS MEETING
June 14 – 16 , 2011
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Medical Diagnostic Equipment Accessibility
David BaquisAccessibility SpecialistU.S. Access Board
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32011 Disability and Health Partners Meeting, June 14 – 16, 2011
Agenda
1. The Access Board2. Accessibility3. The Statute4. Rulemaking Process5. Selected comments from the public
information meeting6. HE75 Standard
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What is the Access Board?
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52011 Disability and Health Partners Meeting, June 14 – 16, 2011
U.S. Access Board
• Independent Federal agency
• Promulgates guidelines and standards for accessible design
• Provides technical assistance and training
• The term “Access Board” is used to refer to the agency staff of the Board, as well as the official Board
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62011 Disability and Health Partners Meeting, June 14 – 16, 2011
The Rulemaking Process
• Public Information Meeting (July 2010)• Notice of Proposed Rulemaking
(anticipated summer 2011)• Public Hearing (during comment period)• (Review public comments, regulatory
assessment, OMB review)• Final Rule (deadline: March 22, 2012)
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What is Accessibility?
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82011 Disability and Health Partners Meeting, June 14 – 16, 2011
Accessible Design
• Design criteria which removes barriers that make it difficult or impossible for some people with disabilities to use MDE
• Rooted in civil rights with intention to provide an assurance of technological non-discrimination
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92011 Disability and Health Partners Meeting, June 14 – 16, 2011
Disability Basics
• People with disabilities account for 20% of the U.S. population
• Many people will develop a temporary disability
• Accessibility helps improve usability for all
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The Statute
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112011 Disability and Health Partners Meeting, June 14 – 16, 2011
Section 510
• Section 4203 of Patient Protection and Affordable Care Act – (Public Law 111-148, 124 Stat. L. 119)
• Added Section 510 to the Rehabilitation Act of 1973 on March 23, 2010
• Title: “ESTABLISHMENT OF STANDARDS FOR ACCESSIBLE MEDICAL DIAGNOSTIC EQUIPMENT”
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122011 Disability and Health Partners Meeting, June 14 – 16, 2011
The Law (1)
Standards ‐ … [Access Board in consultation with … FDA] … setting forth minimum technical criteria for medical diagnostic equipment used in (or in conjunction with) physician's offices, clinics, emergency rooms, hospitals, and other medical settings. The standards shall ensure that such equipment is accessible to, and usable by, individuals with accessibility needs, and shall allow independent entry to, use of, and exit from the equipment by such individuals to the maximum extent possible.
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132011 Disability and Health Partners Meeting, June 14 – 16, 2011
The Law (2)
• Medical Diagnostic Equipment Covered ‐ … shall apply to equipment that includesexamination tables, examination chairs (… eye … dental examinations or procedures), weight scales, mammography equipment, x‐ray machines, and other radiological equipment commonly used for diagnostic purposes by health professionals. …”
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142011 Disability and Health Partners Meeting, June 14 – 16, 2011
Review of Parameters
Patient Access to Medical Diagnostic Equipment:
– by healthcare professionals (Who)– in medical settings (Where)– for diagnostic purposes (Why)
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From the Public Information Meeting (July 2010)
Barriers and Solutions
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162011 Disability and Health Partners Meeting, June 14 – 16, 2011
Featured 6 Panels:
• Consumer perspective• Legal• Healthcare providers• Standards• Industry• Research
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172011 Disability and Health Partners Meeting, June 14 – 16, 2011
Chicago Site Visit with Presentations from staff of:
• Schwab Rehabilitation Hospital• Rehabilitation Institute of Chicago• Northwestern Memorial Hospital• Rush University Medical Center• Access Living (Independent Living Center)
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182011 Disability and Health Partners Meeting, June 14 – 16, 2011
Key to Successful Integration of Accessible Medical Equipment
• Providers need training in the use of accessible medical equipment
• Vendors need to develop training modules to accompany their products
• Awareness of operational differences in medical offices and acute care hospitals
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(c) 11/29/06 Hop Up | [email protected] 19
Accessibility and Usability of Medical Equipment for People with Disabilities: A National Survey
Jill M. Winters, PhD, RN,1 Molly Follette Story, MS,3
Kris Barnekow, PhD, OTR,1 Brenda Premo, MBA,2
June Isaacson Kailes, MSW,2 Erin Schwier, OTD,2R. Sarma Danturthi, PhD,1 & Jack M. Winters, PhD1
1. Marquette University 2. Western University 3. University of California-San Francisco
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202011 Disability and Health Partners Meeting, June 14 – 16, 2011
Survey Results: The Big 4
•Type of Equipment
•Examination tables (n = 291)
•X‐ray equipment (n = 258)
•Rehab/exercise eq. (n = 203)
•Weight scales (n = 222)
•≥ Moderate Difficulty
74.9%
68.2%
55.1%
53.6%
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212011 Disability and Health Partners Meeting, June 14 – 16, 2011
Examination Tables
– Height: too high
– Width: too narrow
– Comfort: hard surface, nothing to lean on
– Getting on: nothing to hold on to
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222011 Disability and Health Partners Meeting, June 14 – 16, 2011
See the Difference
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232011 Disability and Health Partners Meeting, June 14 – 16, 2011
Scoping: How many and where
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242011 Disability and Health Partners Meeting, June 14 – 16, 2011
Paper Cover
• Paper on table is slippery
• However, people who are deaf like the paper for communicating by writing
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252011 Disability and Health Partners Meeting, June 14 – 16, 2011
Stirrups
• Support leg• Articulating• Lock in position• Velcro to help hold in place
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262011 Disability and Health Partners Meeting, June 14 – 16, 2011
Exam Chair Accessible Transfer
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272011 Disability and Health Partners Meeting, June 14 – 16, 2011
Floor Glide Moves ChairOut of the Way
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282011 Disability and Health Partners Meeting, June 14 – 16, 2011
Dental –Back-tilt System
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292011 Disability and Health Partners Meeting, June 14 – 16, 2011
Ophthalmology Equipment onAdjustable Height Table
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Accessible Scales
Stand or Wheel onto it Sit on it or Stand
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312011 Disability and Health Partners Meeting, June 14 – 16, 2011
Imaging Equipment
• General x‐ray• MRI• Mammogram• CT• PET • Bone density
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Compatibility with Ceiling Lift
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332011 Disability and Health Partners Meeting, June 14 – 16, 2011
Mammography Machine
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Pedestals can be a Problem
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352011 Disability and Health Partners Meeting, June 14 – 16, 2011
Considerations: Imaging Equipment
• Mammography Units– Requires dedicated mammography unit with gantry which lowers to permit imaging of the patient in a sitting position. Currently FDA approved units now meet this requirement. Some older units may not meet this criteria.
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362011 Disability and Health Partners Meeting, June 14 – 16, 2011
Positioning with Hausted Mammography Chair
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372011 Disability and Health Partners Meeting, June 14 – 16, 2011
Stereotactic Biopsy:Use of a Stryker cart to transfer
1 3
2 4
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382011 Disability and Health Partners Meeting, June 14 – 16, 2011
HE 75
• ANSI/AAMI HE75‐2009 Human Factors Engineering – Design of Medical Devices
• Chapter 16 posted on AAMI website for complimentary download
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392011 Disability and Health Partners Meeting, June 14 – 16, 2011
Selected Overview of HE 75 (445 Pages; Key Relevant Sections):
Introduction; (1‐3) … 3: DefinitionsGeneral Considerations and Principles (4‐16)4: General Principles5: Managing the Risk of Use Error6: Basic Human Skills and Abilities7: Anthropometry & Biomechanics8: Environmental Considerations9: Usability Testing …16: Accessibility Considerations (pp. 230‐243)Design Elements (18‐21) 18: Controls; 19: Visual Displays …Integrated Solutions (22‐25) … 25: Home Health Care
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402011 Disability and Health Partners Meeting, June 14 – 16, 2011
Research‐based design guidelines for patient support surfaces (HE75 16.4)
• Width of device base• Clearance for lift equipment• Adjustability of surface height• Transfer path• Hand‐holds• Contact surfaces• Controls
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412011 Disability and Health Partners Meeting, June 14 – 16, 2011
Possible Uses of HE 75 Sec 16 Guidance
• Two Classic Approaches:– Design Production Requirements
• Requirements on Products– Ex: Sec 255 of Telecom Act– Ex: FDA Device Evaluation Process
– Purchasing/Procurement Requirements• Equitable Access to Services by Entities
– Ex: Sec 508 (Federal facilities/services)– Ex: “Accessible” fraction [parking spaces, hotel rooms]
• Critical need: Specifications for certification• Possible bodies: Joint Commission; CARF
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422011 Disability and Health Partners Meeting, June 14 – 16, 2011
Coordinated Effort
From “Safe and Effective Access to Medical Devices for All Americans”: The challenge of maximizing safe access to medical products by all patients and practitioners who qualify for use requires an evolutionary process on 3 levels: a) good science aimed at understanding how human‐technology
interfaces affect performance and safe use for a diversity of both devices and people;
b) generation of design guidelines that can help train current and future product designers and engineers in integrating risk analysis with accessible design considerations, and can lead to advances such as certification programs;
c) a vision of social policy change that makes access to medical technology a priority.
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432011 Disability and Health Partners Meeting, June 14 – 16, 2011
Advocacy
• Survey of 379 Massachusetts health care providers found they made access changes based on:– 60% ADA compliance – 49% State requirements – 25% JCAHO and other certifying agencies– 33% PATIENT RECOMMENDATIONS FOR IMPROVEMENT
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442011 Disability and Health Partners Meeting, June 14 – 16, 2011
Benefits of Accessible Design
• Improve “bottom line” via expanded customer base
• Congruency with non-discrimination policies in existence
• Risk management• Strategic planning to prepare for potential
regulations
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452011 Disability and Health Partners Meeting, June 14 – 16, 2011
THE GOAL
EQUAL access to and inclusion of all peopleregardless of type or level of disabilities!– Prevention – Diagnoses– Monitoring and treatment
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462011 Disability and Health Partners Meeting, June 14 – 16, 2011
How to Reach the U.S. Access Board
• Telephone (voice):– 202-272-0013 (direct to David Baquis)– 800-872-2253 (toll-free in U.S.)
• E-mail: [email protected]
• Internet: http://www.access-board.gov
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472011 Disability and Health Partners Meeting, June 14 – 16, 2011
Other Resources
• http://thebarrierfreehealthcareinitiative.org/
• It Takes More than Ramps to Solve the Healthcare Crisis for People with Disabilities (2004)J. Panko Reis, M.L. Breslin, L. I. Iezzoni, K. Kirscher
• The Alliance for Disability in Health Care Education, an organization of health care educators and administrators at American medical schools and nursing schools who are working to promote the inclusion of disability‐related content in health care curricula. http://www.disabilityhealth.org/
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482011 Disability and Health Partners Meeting, June 14 – 16, 2011
“Access to Medical Care for Persons with Mobility Disabilities”
• Joint DOJ (www.ada.gov) & HHS (www.hhs.gov/ocr) technical assistance document, targeting providers (related to ADA, Section 504)
• p. 8‐19 on Part 4: Accessible Medical Equipment– Fully consistent with
Section HE75 16.4. Complementary!
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Questions