National Council on Aging

November 30, 2012

Mr. David M. Capozzi
Executive Director
U.S. Access Board
1331 F Street, NW, Suite 1000
Washington, DC 20004

Re: Best Practice Recommendations for Prescription Drug Labels

By electronic submission to the Access Board

Dear Mr. Capozzi:

The National Council on Aging (NCOA) is a nonprofit service and advocacy organization that serves as a national voice for older Americans and the community organizations that serve them. Our Center for Healthy Aging applies its core competencies to the specific challenge of improving the health of older adults especially those vulnerable and underserved adults living with multiple chronic conditions. NCOA is the national leader in fostering the translation of evidence-based interventions in health promotion and disease/disability prevention into effective programs that can be widely implemented by community-based organizations.

We appreciate the opportunity to submit our recommendations in response to the Access Board's request for best practices for making information on drug container labels accessible to individuals who are blind or visually impaired. We support the Access Board's efforts to convene an 18-member working group of disability advocacy organizations and industry groups to develop the best practices.

Most older Americans cannot afford to pay more for their prescription drugs. In 2010, half of Medicare beneficiaries lived on incomes below $22,000, just under 200% of the federal poverty level and spent on average 15% of their income on health costs.1 More than 1.9 million American adults aged 60 and older who are living at or below 250% federal poverty level ($27,925 per year for a single person) have reported experiencing vision loss.2 Approximately 23.5% of older adults reporting moderate or extreme vision loss indicated that cost or insurance concerns prevented them from seeking eye care.3 The average out-of-pocket health care expenditure for older adults was $4,843 in 2010. Of this expenditure, $805 (17%) was spent on drugs.4 Therefore, solutions developed should have little or no out-of-pocket costs associated with them to ensure low-income older adults have access to the prescription drug containers. This is extremely critical because many of these adults may have multiple chronic conditions requiring several different medications.

NCOA has the following recommendations:

• Prescription drug containers with textured, dark colored lids and an easy-to-use audio device (e.g., similar to ScripTalk® which is used by the Veterans Affairs). This will help visually impaired and blind individuals identify and differentiate their prescription medications.
  
• Medication containers with a large, flat surface to permit labels and instructions to have high contrast printing, large, sans serif letters or fonts designed specifically for the visually impaired (e.g., APHont™) and instructions.
      o Labels should not be affixed upon other labels to permit better readability.
  
• Pharmacists can provide large print, standardized information or print instructions in Braille. Patients suffering from conditions such as neuropathy or those unable to read Braille, can have tactile labels available to them that indicate frequency of drug intake and other critical information.
  
• The use of "Tall Man" letters (e.g., PredniSONE and PrednisoLONE) to differentiate between similar drug names as the Food and Drug Administration has encouraged.5
  
• The use of standardized icons or pictograms to communicate a specific warning or instructions.
  NCOA understands that developing best practices for visually impaired and blind older adults is a challenging process. However, the organization strongly believes solutions should have limited financialimpact on these individuals to ensure all have access to these needed innovations to ensure good health and patient safety.

Sincerely,

Howard Bedlin, JD, MPP
Vice President, Public Policy and Advocacy
Center for Healthy Aging
National Council on Aging
1901 L Street NW, 4th Floor
Washington, DC 20036
Phone: 202-479-6685 | Fax: 202-479-0735
howard.bedlina@ncoa.org

Notes

1. Kaiser Family Foundation. Medicare Policy Fact Sheet. November 2012. Accessed November 29, 2012/ http://www.kff.org/medicare/upload/1066-15.pdf

2. NCOA analysis of the American Community Survey 2010 Public Use Microdata Files.

3. Centers for Disease Control and Prevention. The State of Vision, Aging, and Public Health in America. Atlanta: U.S. Department of Health and Human Services; 2011. Accessed November 28, 2012. http://www.cdc.gov/visionhealth/pdf/vision_brief.pdf

4. Administration on Aging. A Profile of Older Americans: 2011 Health and Health Care. Accessed November 27, 2012. http://www.aoa.gov/aoaroot/aging_statistics/Profile/2011/14.aspx

5. Food and Drug Administration. Name Differentiation Project. Accessed November 26, 2012. http://www.fda.gov/Drugs/DrugSafety/MedicationErrors/ucm164587.htm