Pls don't hesitate to contact me for clarifications on my recommendations
below - Vaishnavi

* Equal Insurance rights for the disabled

   -

   Chapter 13 of the Persons with Disabilities Act 1995 mandates the
   Government to provide / implement insurance schemes for the disabled.



   - India ratified the UN Convention on the Rights of Persons with
   Disabilities (UN CRPD) on 1st October 2007, and has undertaken the
   obligation to ensure and promote the full realization of all human rights
   and fundamental freedoms for all Persons with Disabilities without
   discrimination of any kind on the basis of disability.

   In fulfilment of this international commitment, the country is obligated
   to enact suitable legislation in furtherance of the rights recognized in
   the UN Convention.

   Article 25 of the CRPD relating to health includes the provision to -

(e) Prohibit discrimination against persons with disabilities in the
provision of health insurance, and life insurance where such insurance is
permitted by national law, which shall be provided in a fair and reasonable
manner;


   - Finally, imposition of conditions and denial of policies are arbitrary
   and discriminatory violating Articles 14 (equality before law) , and
   Article 21 (right to life) of the Constitution of India.


Current Status
Pioneering NGO advocating insurance rights for India’s disabled; OASIS,
reports that “People with disabilities have been denied any economic
protection from ill health, for long. This has been one of the reasons of
their poor health seeking behaviour too. The disabled have been denied
Health Insurances because of pre-assumed notions that their disability
results in greater health expenses. Some insurances have however been
offered selectively, but at unaffordable premiums and unacceptable terms
and conditions. Efforts to persuade and convince insurance companies to
give health insurances to persons with disabilities had not resulted in any
success.”

RECOMMENDATIONS (Disability claims of the caused
death-dismemberment-disability type are not covered below. Neither are
long-term /short-term disability benefits, loss of future income cases etc.
These focus primarily on access to insurance and resulting discrimination)

Policies for All : While working towards the ideal of statutory universal
health insurance coverage, keeping in mind the opening of the insurance
market in India, policies may not be denied unless in cases of fraud. Where
healthcare is unaffordable to the insured, the enhanced loading on premium
should be contributed / underwritten by the State within reasonable limits.
This would protect both the consumer and wherever relevant, the insurance
company from unjustifiable hardship in high-cost (not high-risk) cases.

Condition-al Exclusion : While presence of a pre-existing condition /
disease is best declared upfront for reasons of transparency, such
disclosure shall not be grounds for premium loading without justification
by way of recent, regional  actuarial data or exclusion of disease from
insurance policy / denial of coverage for said condition / forced switch to
another policy.

Patching up Gaps : The recognition and inclusion of AYUSH as equal
alternative to allopathic health care in welcome.  However, as the future
market will be largely private-insurance company driven, some critical
aspects of health care may be missed due to profit-focussed cherry-picking.
Eg : rehabilitation, all kinds of therapy, domiciliary care, hospice care,
daycare / OP (days lost expenses and travel) etc are provided as add-ons by
very few schemes despite their inclusion in ICD-10-PCS - which is quoted
liberally throughout the draft. These should be identified and mandated
statutorily by the State.

While initiatives so far for disabled people vis-a-vis insurance are
appreciated, given that disability can happen to anyone at anytime, it is
in the interest of society at large that instead of standalone insurance
products specially for disabled groups, disabled people and other such
vulnerable / discriminated citizens be included in mainstream insurance
schemes. State-sponsored health insurance schemes of Andhra Pradesh & Tamil
Nadu have already demonstrated such an inclusive approach.

Add-ons which are frequently overlooked like pregnancy cover, neonate cover
to be publicised or built into standard schemes.

Proof against Prejudice : Data from the Niramaya Scheme, OASIS and other
private offerings, existing products and by companies actual sales
under Obligations
of Insurers to Rural or Social Sectors) Regulations, 2005 to be developed
instead of prejudicial / assumption-based risk. Defaulting companies who
have not managed their quota under 2005 regulations may be penalised with
timebound provision of the same gratis for a period of 7 years. This
actuarial, statistical database should be linked to justification for any
transfer by Insurance Company  for co-contribution by the State. Based on
this data, appropriate State Departments like Health, Transport, Industry,
Disaster Management, Social Welfare etc can contribute their ‘share’
respectively to the State’s Corpus for high-cost, unaffordable insurance
claims.

Accessibility : Till such time anti-discrimination measures yield more
equitable insurance coverage for all citizens, the current provision for
‘Senior Citizens Helpline’ and allied services may be extended to people
with disabilities and other currently disadvantaged / discriminated groups
as a ‘Policyholder Protection Helpline’.

In addition to compliance with the National Building Code Accessibility
Section, GIGW & WCAG 2 guidelines; insurance infrastructure and services
must be compatible for disabled / disadvantaged groups by way of simple
language in media, alternative formats, documents, forms, ads, websites,
data etc. Communication by way of sms, sign language, braille, aac,
vernacular languages to be recognised and accommodated and Customer
Information Sheet must be provided in a variety of media / formats /
languages.*


On 29 June 2012 18:49, rahul cherian <[email protected]>wrote:

> Hello all,
>
> Please find attached the input on the draft health regulations prepared
> with input from Mr. Harish Kotian, Ms. Meenakshi Balasubramaniam, Dr.
> Maneesh Gupta, Mr. Rajive Raturi, Ms. Poonam Natarajan and Ms. Reshma
> Valliapan. If I have misunderstood any of your input, made any mistakes or
> left anything out, please let me know asap.
>
> For the others, if there is anything you would like to change, add or
> delete please email me before 12 pm tomorrow. Sorry for the short deadline
> but I have to send it out by 4.30 pm tomorrow.
>
> Also, if you want to add the name of your organisations to this note do
> email me before 12 pm tomorrow.
>
> Thanks,
>
> Rahul Cherian
> Inclusive Planet Centre for Disability Law and Policy
> +91 98403 57991
> ++++++++++++++++++++++++++++++++++++++++++++++++++++++
> For more information about our work visit www.inclusiveplanet.org.in
>

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