Many people attempting to access healthcare and nutrition benefits under a variety of federal programs, such as Medicaid, Supplemental Nutrition Assistance Program, and Pandemic EBT, encounter barriers to access based on disability, national origin, or other discriminatory reasons. However, complaints documenting these barriers filed with the appropriate federal agency have been routinely dismissed without any indication of a genuine investigation.

In July, with the assistance of Democracy Forward, the Tennessee Justice Center provided a comment to OMB, outlining its experience representing clients seeking healthcare and nutrition benefits and notifying OMB that systemic failures in administrative enforcement exacerbate inequities shouldered by underserved communities. This comment was submitted as part of an OMB request for information on methods and leading practices for advancing equity and support for underserved communities through government.

TJC’s comment also included a proposed solution to the above problem: investigative standards and procedures should be established for how Offices for Civil Rights across federal agencies review complaints. To that end, the comment recommended an audit of discrimination complaints filed with all federal agencies over the past decade, which may help identify patterns of inadequate redress, and may help inform how the new standards for investigating potential discrimination can promote equity.

Read the entire comment here.