Practice Management Alert

Follow these guidelines for exam room accessibility and ADA compliance.

The tenets of the Americans with Disabilities Act (ADA) provide for equal and complete access to services and resources, regardless of mobility and ability.

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) has a handy resource for medical establishments to make sure they are equipped for treating patients, regardless of their mobility or abilities, while also keeping staff safe from workplace injury.

Title II and Title III of Section 504 of the ADA outline the requirements that people with mobility disabilities must be ensured:

• “full and equal access to their health care services and facilities; and
• “reasonable modifications to policies, practices, and procedures when necessary to make health care services fully available to individuals with disabilities, unless the modifications would fundamentally alter the nature of the services (i.e. alter the essential nature of the services).”

Use the following tips and clarifications to better understand your responsibilities as a practice and a practitioner.

Understand the Infrastructure Requirements

The OCR lists certain features as necessary for physical accessibility. Some are bigger infrastructure necessities, like doorways of a particular size with a certain kind of hardware, but other features are equipment that you can purchase and put into exam rooms.

The OCR says an “accessible examination room has features that make it possible for patients with mobility disabilities, including those who use wheelchairs, to receive appropriate medical care. These features allow the patient to enter the examination room, move around in the room, and utilize the accessible equipment provided. The features that make this possible are:

• “an accessible route to and through the room;
• “an entry door with adequate clear width, maneuvering clearance, and accessible hardware;
• “appropriate models and placement of accessible examination equipment; and
• “adequate clear floor space inside the room for side transfers and use of lift equipment.”

Making sure your facility is navigable with a wheelchair allows patients to access care, but it’s important to have exam room facilities that are accessible as well.

Prioritize Equipment that Promotes Equal Access

Having the equipment that allows equal access to care is crucial. For example, although you may usually examine patients in a seated position, you should not equate an examination of a patient in a wheelchair with that which you would conduct for a patient on an exam table.

“Examining a patient in their wheelchair usually is less thorough than on the exam table, and does not provide the patient equal medical services. There are several ways to make the exam table accessible to a person using a wheelchair. A good option is to have a table that adjusts down to the level of a wheelchair, approximately 17-19 inches from the floor,” the OCR says.

Similarly, if you currently lack equipment that is or can be made accessible to people with mobility disabilities, you cannot use the lack of equipment as a reason to not see a patient.

“You cannot deny service to a patient whom you would otherwise serve because she has a disability. You must examine the patient as you would any patient. In order to do so, you may need to provide an accessible exam table, an accessible stretcher or gurney, or a patient lift, or have enough trained staff available who can assist the patient to transfer,” the OCR says.

Note: While restaurants and other public facilities generally get away with having only one handicapped accessible bathroom stall, the ADA is explicit in its requirement to provide equal and consistent access to medical care. The OCR says that it is “generally not OK” to make a patient wait, if, for example, you only have one accessible exam table and that room is occupied by someone else.

One way to combat this is to instruct your scheduling staff to ask every patient if he will need any assistance at the appointment due to a disability. Also, make sure the patient’s chart notes his mobility challenges and to make sure you have the room with the accessible exam table ready and reserved for that patient. If you cannot make such a scheduling accommodation, strongly consider equipping more exam rooms, or every exam room, with a handicapped accessible exam table.

Understand Etiquette for Companions

Though a person with a mobility disability may rely on an aide to assist with activities of daily living like dressing or moving into different positions, the ADA specifies that medical staff cannot request that a patient bring a companion or aide to an appointment.

“If a patient chooses to bring along a friend or family member to the appointment, they may. However, a patient with a disability, just like other individuals, may come to an appointment alone, and the provider must provide reasonable assistance to enable the individual to receive the medical care,” the OCR says.

You or staff may need to provide assistance to make the exam possible. “This assistance may include helping the patient to undress and dress, get on and off the exam table or other equipment, and lie back and be positioned on the examination table or other equipment. Once on the exam table, some patients may need a staff person to stay with them to help maintain balance and positioning. The provider should ask the patient if he or she needs any assistance and, if so, what is the best way to help,” the OCR says.

Important: Even if making accommodations for a patient with a disability takes more time than seeing a patient who does not have mobility challenges, you cannot charge a patient’s insurance for the extended examination time. “You cannot refuse to treat a patient who has a disability just because the exam might take more of your or your staff’s time. Some examinations take longer than others, for all sorts of reasons, in the normal course of a medical practice,” the OCR says.

Resource: For more information on the specific accessibility requirements your practice must follow, see https://www.ada.gov/medcare_mobility_ta/medcare_ta.htm.