The MDE Standards are intended to allow for independent access to and use of medical diagnostic equipment by individuals with disabilities to the maximum extent possible. This section will examine the barriers to health care that individuals with disabilities encounter due to inaccessible medical equipment, and then explain how diagnostic equipment conforming to the MDE Standards will benefit individuals with disabilities.

5.1. Barriers to Medical Equipment and Health Care

Accessible medical diagnostic equipment appears not to be available at many health care providers and facilities. While the Access Board is unaware of any national data on the prevalence of accessible medical diagnostic equipment currently installed in medical facilities, data from specific states and types of equipment indicates that much of that equipment is not accessible. In California, a recent study of about 2,400 primary care facilities serving Medicaid patients in the state found that only 8.4 percent of the facilities had a height-adjustable examination table and less than 4 percent had a weight scale that could be used by patients who have mobility or activity limitations or who exceed the standard weight scale limit.8 Similarly, one medical device manufacturer that participated in the MDE Advisory Committee estimates that approximately 70% of examination rooms in the United States have only fixed-height tables, which present difficulties to many patients with disabilities.9

Evidence from surveys and focus groups confirms that individuals with disabilities face many significant barriers to accessing medical devices and technology. A 2004 national consumer survey collected information on the types of medical equipment that are most difficult for individuals with disabilities to access and use.10 A diverse sample of individuals with a wide range of disabilities completed the survey, including people with mobility, visual, hearing, and speech impairments, as well as individuals with cardiopulmonary conditions resulting in activity intolerance, orthopnea, and dyspnea. Survey respondents rated their degree of difficulty when attempting to access or use the equipment as follows:

Survey respondents reported difficulties of getting on and off the equipment, positioning their bodies on the equipment, feeling physical comfort and safety, interpreting visual displays and markings, and undertaking activities requiring fine motor movements.

To identify the critical barriers to accessibility and usability, the consumer-survey researchers conducted an in-depth focus group study of individuals with disabilities.12 The researchers delved into specific equipment-related difficulties. Among other things, the participants commented on lack of physical supports for patients with disabilities to transfer their bodies onto and off the equipment and lack of support to achieve and maintain body positions while on the equipment. Expressing a range of emotions such as fear, frustration, embarrassment, and indignation, the focus group participants described some medical equipment (e.g., examination tables, imaging equipment, medical chairs, and weight scales) as not only inaccessible but also scary and unsafe. Some even reported that the negative health care experiences affected their willingness to schedule regular medical examinations and diagnostic procedures.

Furthermore, according to the National Council on Disability (NCD), the lack of accessible examination equipment is one of the greatest barriers to quality health care. NCD’s 2009 report entitled “The Current State of Health Care for People with Disabilities” states:

For many people with mobility disabilities, access to examination and diagnostic equipment such as mammogram machines can be difficult or impossible if the equipment is not height-adjustable. Medical office staff members often are not trained to provide lifting assistance and are unwilling to lift patients onto inaccessible examination tables. Some patients do not wish to be lifted, out of fear that they will be dropped or injured. Health care providers, therefore, frequently conduct examinations or diagnostic tests while patients are seated in their wheelchairs, which can generate inaccurate test results or conceal physical evidence required for appropriate diagnosis and treatment.13

The Center for Disability Issues and the Health Professions (CDHP) also stresses that the lack of accessible equipment reduces the likelihood that individuals with disabilities will receive timely and appropriate health care. Health care providers may not perform some diagnostic procedures for patients with disabilities because the providers lack accessible equipment. This can result in suboptimal examination, missed or delayed diagnoses, and worsening conditions that require more expensive and extensive treatments.14

5.2. Potential Benefits of the MDE Standards

The MDE Standards aim to lower the barriers that individuals with mobility and communication disabilities encounter while attempting to access and use medical diagnostic equipment. More specifically, many technical specifications in the Standards are intended to reduce barriers facing individuals with mobility disabilities, while one provision (concerning communication through diagnostic equipment) aims to help people with vision or hearing impairments. Medical diagnostic equipment complying with the technical requirements of the MDE Standards will increase accessibility by facilitating independent entry to, use of, and exit from such equipment by persons with mobility and communication disabilities, thereby improving the overall quality of their health care. By allowing individuals with disabilities to receive examinations, diagnostic procedures, and other health care services comparable to those received by individuals without disabilities, accessible medical diagnostic equipment will contribute to the improvement of the overall quality of health care for individuals with disabilities. The following examples demonstrate how the technical requirements of the MDE Standards will address specific barriers that people with mobility and communication disabilities face when trying to use the noted types of medical diagnostic equipment.

Examination Tables

The examination tables used in many examination rooms in the United States are fixed-height and are therefore not accessible.15 The surface of fixed-height examination tables is usually at least 30 inches off the floor—too high for a person in a wheelchair to transfer independently onto the table. These examination tables typically lack handholds or other transfer supports that help individuals transfer from a mobility device to the table surface. Consequently, individuals who use mobility devices are rendered dependent on the assistance of others to transfer them onto a table, with or without a portable patient lift. Not every doctor’s office has a portable patient lift, and transfer without proper equipment can pose a risk of injury both to the person being transferred and to the person assisting with the transfer. As a result, some medical practices routinely have patients remain in their wheelchairs during an examination, instead of transferring the patients to an examination table for a proper exam. Such substandard care can prevent proper diagnosis and treatment of serious medical conditions. For example, in a complaint filed against a major health maintenance organization (HMO), a plaintiff described how when he had sought medical care for pressure sores, the doctor never personally examined the sores because the facility did not provide any way for the plaintiff to transfer from his wheelchair to the facility’s fixed-height examination tables.16 The plaintiff stated that he had no way of knowing the severity of his condition, and if he was being properly treated.

Under the MDE Standards, accessible examination tables must be height-adjustable, with a low transfer height of 17-19 inches, a high transfer height of 25 inches, and 4 intermediate transfer heights (M301.2.1). If a patient is able to transfer independently to an examination table, this adjustability allows the patient to select the best transfer height for the examination table; the table can then be raised to an appropriate level for diagnosis and later lowered so that the patient may transfer back to his or her mobility device. The MDE Standards also ensure that the transfer surface of an accessible examination table is appropriately wide for transfer (M301.2.3), that the surface is unobstructed during transfer (M301.2.4), and that transfer supports are provided to facilitate transfer (M301.3.1). For patients who are not able to transfer independently, the MDE Standards require accessible examination tables to be compatible with a portable patient lift (M301.4) so that the patients can transfer via the lift, if there is one. Examination tables meeting the MDE Standards will allow patients to receive examinations on an exam table comparable to those patients without disabilities receive.

Weight Scales

Many doctor’s offices have stand-on weight scales with a small standing surface and no handrails. Such scales pose challenges for individuals who use wheelchairs, who have balance issues, or who have other mobility impairments. Accurately assessing weight is critical for appropriate diagnosis and treatment of certain conditions. Individuals unable to use the scale provided at their doctor’s office report being asked to guess their weight.17 The potential use of an inaccurate weight is particularly concerning when medical professionals use that reported weight in prescribing or evaluating medication dosages. Individuals report that it is difficult to maintain balance on stand-on scales as there is nothing to hold on to. Even wheelchair scales are not necessarily fully accessible: some wheelchair users indicate that they are asked to stand once on the scale to be weighed without the weight of the wheelchair, and that this posed a challenge for them.

The MDE Standards provide technical specifications that can be applied to stand-on scales, wheelchair scales, and chair scales to make each type of scale more accessible. For accessible stand-on scales, the MDE Standards require that the standing surface be slip-resistant (M304.2.1) and that standing supports be provided (304.2.2). For accessible wheelchair scales, the MDE Standards require a sufficiently large platform to provide wheelchair access (M303.2.2 and M303.2.3), minimal slope in the platform surface (M303.2.5), edge protection to keep the wheelchair from rolling off a raised platform (M303.2.6), appropriate ramping or beveled edge at the entry of a raised platform (M303.3), and a standing support if the scale is also to be used by patients in a standing position (M304.2.2). Under the MDE Standards, accessible chair scales must be height-adjustable (M302.2.1), must have transfer supports (M302.3), and must provide for unobstructed transfer (M302.2.5). These technical requirements address transfer and balance issues that patients with disabilities face when using weight scales at medical facilities.

Examination Chairs

When patients with disabilities seek specialized medical care, they may confront inaccessible examination chairs that are difficult to transfer into and out of. Further, specialized examination chairs are typically designed with special features to assist in diagnosis, and these features may not be compatible with certain types of disabilities. For example, standard heel stirrups used on many obstetrics and gynecology (OB/GYN) chairs are insufficient to position properly the legs of a patient with limited leg strength. Phlebotomy chairs are often fixed-height, with much of the transfer surface permanently obstructed by fixed armrests. Dental chairs have integrated leg rests, and attached equipment often fully obstructs one side of the chair. This configuration presents serious challenges to patient transfer, requiring that transfer occur on a specific side of the chair, typically without the presence of transfer supports. Due to the inaccessibility of specialized examination chairs, individuals with disabilities may go for years without specialty medical care. For example, a woman who uses a wheelchair reported that because her HMO provider did not have sufficiently accessible equipment, she was routinely examined while seated in her wheelchair.18 As a result, the woman had not had a gynecological exam in 15 years. Another woman with lower-body paralysis indicated that for her to have a gynecological exam, two people are needed to hold her feet in the stirrups.19

The MDE Standards require accessible examination chairs to be height-adjustable for transfer (M302.2.1), and that the transfer surface be unobstructed during transfer (M302.2.5). Further, they require a patient to be able to transfer from two different sides of the chair, either from the front and the side, or for chairs with an integrated leg rest (such as a dental chair), from either side of the chair (M302.2.4). Accessible examination chairs must also have transfer supports that patients can use to facilitate transfer (M302.3.1). These requirements allow an accessible examination chair to be repositioned to a height that is optimal for a particular patient to transfer, provide an unobstructed surface so the patient does not need to navigate around equipment or armrests, allow the patient to use his or her stronger side for transfer, and have transfer supports for stability during transfer. In addition to the requirements related to patient transfer, the MDE Standards require that if stirrups are provided, they must support, position, and secure the patient’s legs, so that she need not rely on her own leg strength for proper diagnostic positioning (M305.4). MDE Standards require head and back support while an examination chair is reclined to support patients who lack back and neck muscle strength (M302.3.3). These technical requirements facilitate independent transfer into specialty examination chairs, and provide independent positioning support for proper diagnostic use.

Imaging Equipment

Several types of imaging equipment pose challenges to people with disabilities. For example, it is well documented that women with mobility disabilities are less likely to obtain mammograms.20 To use a typical mammography machine, a patient must stand during imaging, with her breast positioned on a platform. Some patients with disabilities do not have the lower body strength to stand for this procedure. The MDE Standards address access to mammograms by providing technical specifications for mammography machines that are used while a patient is seated in a wheelchair (M303). The MDE Standards specify technical requirements for the height of the breast platform, which must be adjustable enough to allow use by an individual in a wheelchair (M303.4.1), and for clearances that will allow a wheelchair to fit under a breast platform (M303.2.4.1).

Other types of imaging equipment also present barriers to access. Fixed-height radiology tables are difficult for patients to transfer onto, as are fixed-height CT scanners and MRI beds. Imaging equipment rarely have any type of transfer supports. In addition, fluoroscopy machines that rotate patients from a lying position to a standing position do not have standing supports when they are used in a standing position. The MDE Standards require the examination surface of accessible imaging tables to be adjustable (M301.2.1) unless such adjustability is impossible to achieve due to structural or operational characteristics (M201.2). In addition, the Standards also require transfer supports and an unobstructed transfer surface to facilitate patient transfer. The MDE Standards also specify that accessible imaging tables be compatible with portable patient lifts (M301.4), so even if a patient is unable to transfer independently onto imaging equipment, he or she can be transferred using a lift. Standing supports are required for accessible equipment that has a standing surface, such as a fluoroscopy machine, which will allow patients with limited leg strength or balance issues greater stability while the machine is in a standing position.

In sum, when applied, the technical requirements of the MDE Standards will remove specific barriers to the use of medical diagnostic equipment by persons with mobility or communication disabilities. Equipment complying with these MDE Standards will allow many individuals with such disabilities to transfer independently onto and off of diagnostic equipment, receive improved diagnostic procedures, and maintain their sense of independence, confidence, and dignity while using medical services.

5.3. Potential Beneficiaries – People with Disabilities

The U.S. Census Bureau estimates that approximately 56.7 million people, or 18.7%, of the U.S.’s civilian non-institutionalized population had some level of disability in 2010.21 To put this in perspective, the number of individuals with disabilities in the United States is very close to the combined total population of California and Florida. The Census Bureau provides the following estimates regarding the number of people aged 15 and older with specific disabilities:

Moreover, the need for accessible MDE will increase in the coming decades for demographic reasons. The prevalence of disability increases with age: the U.S. Census Bureau’s American Community Survey shows that in 2014, 36% of people age 65 and over had some type of disability, compared with 10.5 % of people who are younger (ages 18-64).22 And this group is growing: already, 46.2 million persons – or one in 7 Americans – were at least 65 years old in 2014, and the elderly population is projected to more than double over the next 35 years, to approximately 98 million in 2060.23

Medical equipment conforming to the MDE Standards will benefit many people with mobility and communication disabilities when they seek health care services, with particular benefits for those individuals who have the greatest health care needs. The final report submitted by the MDE Advisory Committee describes the varying degrees of health care needs by individuals with disabilities as follows:

On one level, most persons with disabilities require the same services recommended for all individuals to maintain their health and diagnose diseases at early, more treatable stages. . . Many persons also require specific diagnostic and therapeutic services because of the health conditions causing their functional impairments and disability. Other persons might need diagnostic testing or therapeutic treatments to address secondary disabilities or conditions related to their primary disabilities. In addition, as they age, persons with disabilities experience many of the same chronic conditions as do other in late middle-age and older years, such as hypertension, diabetes, cardiovascular and pulmonary diseases, and cancers, necessitating the full range of diagnostic and therapeutic health care services.24