Responding to a Denial

Step 5: Suggested Language for Requesting “Reasonable Accommodations” Under the Americans with Disabilities Act

Suggested language:

People with bleeding disorders are protected under the Americans with Disabilities Act, and facilities are required to provide reasonable accommodations to ensure that they have equal access to their facilities. This person requires some reasonable accommodations to ensure equitable access.

Suggested language when discussing people with BD who self-infuse/inject BD medication:

The patient has a chronic health condition that they manage independently. However, they may need some reasonable accommodations to ensure equitable access to your facility. Specifically, the patient self-administers medication that should be taken in private and stored at the facility.
Some bleeding disorder medications require the use of a very small butterfly needle for an IV push infusion or injection. This medicine is very important for maintaining the patient’s health and medical stability and needs to be continued while at your facility.

The infusions used to treat bleeding disorders are fast (usually 5-10 minutes), safe (are not associated with adverse events), do not require IV poles, hanging IV bags, or pumps, and do not typically require any medical oversight that would take them away from the facility.
The subcutaneous injection is similar to treatments used by people with diabetes.

The patient’s bleeding disorder treatment team believes that it is appropriate for the patient to self-administer their bleeding disorder medication both at home and at your facility.

This patient is completely self-sufficient with their care and infuses/injects their own medication when needed.
Self-infusion/injection of their bleeding disorder medication is part of this person’s normal activities of daily living.
People with bleeding disorders are usually taught to self-infuse/inject their bleeding disorder medication during elementary school.
The patient is fully competent to self-administer their bleeding disorder medication and does not require medical supervision for this process. (For SUD facilities, suggest that a staff member may need to monitor the infusion process to ensure that no other substances are infused).

I would be happy to brainstorm some reasonable accommodations with you to ensure that this patient has access to their medication while at your facility.

Suggested language when discussing people with BD who require assistance infusing/injecting BD medication:

Patient has a well-controlled medical condition that requires regular treatment. The patient may need some reasonable accommodations to ensure equitable access to your facility.
This person uses a medication to manage their BD that requires the use of a very small butterfly needle for an IV push infusion or injection.
Use of this medication is part of this person’s normal activities of daily living.
The infusions used to treat bleeding disorders are fast (usually less than 5 minutes), safe (are not associated with adverse events), do not require IV poles, hanging IV bags, or pumps.
The subcutaneous injection is similar to treatments used by people with diabetes.
Infusions/injections do not typically require any medical oversight or regular lab work that would take them away from the facility.
The patient requires assistance to administer their bleeding disorder medication. This can be given by a provider at the facility. If you do not have a provider who is able to give their medication, we would be happy to work with your medical director to develop a plan of care.

Sometimes the mere mention of the facility’s federal obligations is enough to encourage the facility to reconsider their decision. However, if they are not moved by a conversation alone, it will be important to put the request for reasonable accommodations in writing.The request letter (or email) may be sent by the provider or the person being denied access. The goal of the letter is to encourage the facility to engage with you about how they can ensure that your patient has access to required medication while receiving treatment at their facility. This request letter is intended to initiate a conversation between the facility and your provider about how they can best accommodate the person with BD at their facility.

The behavioral health facility may not give you exactly what you request (for example, they may not let a person with BD self-infuse), but it is important that they admit the person and permit access to BD medication during their stay. For some creative solutions that other facilities have adopted, please see the resource “Brainstorming potential solutions to the question of infusions.” Please keep in mind that behavioral health facilities are regulated at the state level, so what is permitted in one state or locality, may not be in another.

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On this website, the term “behavioral health” includes both mental health and substance use disorder.

Responding to a Denial

Suggested language:

People with bleeding disorders are protected under the Americans with Disabilities Act, and facilities are required to provide reasonable accommodations to ensure that they have equal access to their facilities. This person requires some reasonable accommodations to ensure equitable access.

Suggested language when discussing people with BD who self-infuse/inject BD medication:

The patient has a chronic health condition that they manage independently. However, they may need some reasonable accommodations to ensure equitable access to your facility. Specifically, the patient self-administers medication that should be taken in private and stored at the facility.

Some bleeding disorder medications require the use of a very small butterfly needle for an IV push infusion or injection. This medicine is very important for maintaining the patient’s health and medical stability and needs to be continued while at your facility.

The infusions used to treat bleeding disorders are fast (usually 5-10 minutes), safe (are not associated with adverse events), do not require IV poles, hanging IV bags, or pumps, and do not typically require any medical oversight that would take them away from the facility.

The subcutaneous injection is similar to treatments used by people with diabetes.

The patient’s bleeding disorder treatment team believes that it is appropriate for the patient to self-administer their bleeding disorder medication both at home and at your facility.

This patient is completely self-sufficient with their care and infuses/injects their own medication when needed.

Self-infusion/injection of their bleeding disorder medication is part of this person’s normal activities of daily living.

People with bleeding disorders are usually taught to self-infuse/inject their bleeding disorder medication during elementary school.

The patient is fully competent to self-administer their bleeding disorder medication and does not require medical supervision for this process. (For SUD facilities, suggest that a staff member may need to monitor the infusion process to ensure that no other substances are infused).

I would be happy to brainstorm some reasonable accommodations with you to ensure that this patient has access to their medication while at your facility.

Suggested language when discussing people with BD who require assistance infusing/injecting BD medication:

Patient has a well-controlled medical condition that requires regular treatment. The patient may need some reasonable accommodations to ensure equitable access to your facility.

This person uses a medication to manage their BD that requires the use of a very small butterfly needle for an IV push infusion or injection.

Use of this medication is part of this person’s normal activities of daily living.

The infusions used to treat bleeding disorders are fast (usually less than 5 minutes), safe (are not associated with adverse events), do not require IV poles, hanging IV bags, or pumps.

The subcutaneous injection is similar to treatments used by people with diabetes.

Infusions/injections do not typically require any medical oversight or regular lab work that would take them away from the facility.

The patient requires assistance to administer their bleeding disorder medication. This can be given by a provider at the facility. If you do not have a provider who is able to give their medication, we would be happy to work with your medical director to develop a plan of care.