On behalf of Legal Services for Seniors, I wish to comment on the 10% threshold for translating Medicare plan materials that is codified here. Legal Services for Seniors is a non-profit law firm providing free legal services to Monterey County California seniors 60+ of age and over. As a long-time attorney and Executive Director of Legal Services for Seniors, I can state by personal experience working with these regulations that the 10% standard is far too high. A more appropriate standard would be "5% of population, or 500 persons in service area."
Many of our clients are mono-lingual Spanish speaking, many more are illiterate in any language. Please ensure these clients are affordaed continued access to their records at a cost they can afford.
Thak you.
Kellie D. Morgantini
Executive Director, Attorney
Legal Services for Seniors
office: 831.899.0492/831.442.7700
cell: 831.674.5863
www.legalservicesforseniors.org
Morgantini, Kellie--CA
This is comment on Proposed Rule
Medicare Program: Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs for Contract Year 2012
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