November 30, 2012
Mr. David M. Capozzi
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:
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
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