JFActivist

June 24 is National Call-In Day for the ADA Amendments Act of 2008!

***ACTION ALERT!

Tomorrow is NATIONAL CALL-IN DAY for the ADA Amendments Act. Thousands of advocates all across the country representing all kinds of disabilities will be calling their representatives to tell them to support the ADA Amendments Act of 2008. You can help!

Last week, the House Judiciary and Education and Labor Committees overwhelmingly passed the ADA Amendments Act of 2008 (formerly known as the ADA Restoration Act).

Although nothing has been confirmed, the bill could be going to the House floor for a vote as early as Wednesday of this week, so it's important that Members hear from us ASAP! We need your help to make sure the bill becomes law.

The ADA Amendments Act will reverse judicial decisions that permit job discrimination against people with all kinds of disabilities. The bill enjoys the support of over 60 national disability groups, including AAPD, as well as experts in the disability community, business and employer groups, and Members of Congress.

We need your help! Our goal is to have the ADA Amendments Act passed by the entire House of Representatives with no amendments.

You can help by calling your Representative on Tuesday, June 24 with the following message:

• "I am calling to express my strong support for the ADA Amendments Act of 2008 <as a person with a disability or as a family member of a person with a disability>. This bill would protect people like <me or my family member> and is supported by the disability and business communities. I urge you to vote in favor of the bill without any amendments and without a motion to recommit!"

You can reach your Representative through the Capitol Switchboard at:

(202) 224-3121 (voice)
(202) 224-3091 (TTY) 

Additional background information is available below.

Background:

The Americans with Disabilities Act has transformed the nation since its enactment in 1990. The ADA was intended to protect people with disabilities from discrimination at work and in public life.

Unfortunately, court decisions over the last decade have excluded individuals who should have been covered under the ADA. These judicial restrictions block people with conditions including epilepsy, diabetes, multiple sclerosis, muscular dystrophy, intellectual disabilities, cancer, heart disease, and bipolar disorder from seeking protections against employment discrimination under the ADA.

The ADA Amendments Act of 2008 will re-establish these protections. This legislation is supported by over 60 national disability organizations - including AAPD - and many key business associations such as the U.S. Chamber of Commerce, the National Association of Manufacturers, the Society for Human Resource Management, and the HR Policy Association.

The ADA Amendments Act of 2008 will:

• Amend the current Americans with Disabilities Act so that the effects of "mitigating measures" such as medications, hearing aids, and prosthetics, could not be used in determining whether an individual is disabled.
• Make it clear that Congress intended the ADA's coverage to be broad, to cover anyone who faces unfair discrimination because of a disability.
• Clarify the current requirement that an impairment substantially limits a major life activity in order to be considered a disability. The legislation provides a reasonable standard that will give clarity to employers and access to protections from unlawful discrimination for people with disabilities.

Urge Congress to Increase Funding for Family Support

***ACTION ALERT***

Submitted by: Association of University Centers on Disabilities (AUCD)

Beginning right now and throughout the summer, Congress will be deciding how much money to provide federal programs for the coming year.  There are several key programs that provide family support but they are seriously underfunded.  Your help is needed in educating Members of Congress about why it is important to provide more money for family support programs.

Action Needed:
Contact members of the House and Senate Labor-HHS-Education Appropriations Subcommittees.  Urge them to provide additional funding for family support programs at the levels recommended below, which are consistent with recommendations from the Consortium for Citizens with Disabilities (CCD).

Members of Senate Labor-HHS-Education Appropriations Subcommittee

Members of House Labor-HHS-Education Appropriations Subcommittee

You can contact members of Congress by calling the Capitol switchboard: (202) 224-3124.

You can also click here to send your members of Congress a prepared e-mail message through the AUCD Action Center.   

Background:
While over 80% of all long-term services and supports are delivered informally, little funding is provided to support family and other informal caregivers.  Investing in family support is fiscally wise.  The economic value of informal caregiving is over $350 billion a year.  American businesses lose between $17.1 and $33.6 billion annually in lost productivity costs due to family members providing informal supports.  Respite and other supports contribute to the well-being of caregivers and can reduce undesirable, costly placements in nursing homes and other institutions.  Funding for programs that provide family support has not kept pace with growing demands and pressures on families.  Three important programs are: 

1. National Family Caregiver Support Program
   The National Family Caregiver Support Program (NFCSP) is authorized under Older Americans Act.  It is intended to provide a variety of supports to caregivers of older individuals and older caregivers of children and adults with disabilities.  Funding for the NFCSP has not kept pace with an aging population and actually received a slight cut last year.  It is currently funded at $153.4 million; it is recommended that Congress increase funding to $250 million for FY 09.
   
   
   
2. Lifespan Respite Care Act
   The Lifespan Respite Care Act was signed into law on December 21, 2006.  It is intended to provide competitive grants to assist states in developing statewide respite systems to make quality respite available to family caregivers regardless of age or disability.  However, it has not yet received any funding to be implemented. It is recommended that Congress provide funding at the full authorization level of $53.3 million for FY 09.
   
   
   
3. Family Support Program
   Title II of the Developmental Disabilities Act authorizes the Family Support Program to promote and strengthen systems of family support services to families with relatives with developmental disabilities.  Currently, only 21 states receive grants and funding is provided through a different section of the Act.  It is recommended that funding for family support be increased from approximately $7.2 million to $17 million for FY09 to allow every state and US territory to receive grants.  It is also recommended that this funding be provided through Title II without negatively impacting funding for other initiatives within Projects of National Significance.                  

Billboard Alert!

The billboard depicted here (which reads, "Think seatbelts are confining? Try a wheelchair. Buckle up") was erected by the Ravalli County DUI Task Force in Montana. The Task Force reports to the Ravalli County Board of Commissioners.

We are told that in general, the Task Force does good work, however, this billboard demonstrates that they could take stand some lessons on disability culture and etiquette.

REACT!

Advocates interested in sharing their opinions can do so in a number of ways:

• Email the commissioner of Ravalli County and tell him that while perhaps well-intended, the billboard is an insult to people with disabilities.
• Write a letter to the editor of the local newspapers. Send letters to the Ravalli Republic  Managing Editor, Perry Backus and to Missoulian using their online form.
• Post a reaction on the JFActivist blog.

Have you seen or heard an ad lately that you find shocking? Share it with the JFA Moderator.

Under 30 in a Nursing Home

The following article in The New York Times highlights the number of children and young adults living in nursing homes and other institutions whose family feel daunted by the prospect of finding them the most suitable location for care. The article reports that there are roughly 8,000 such people under the age of 30 living in nursing homes today.

The author spends little time exploring home and community-based alternatives to institutional settings, but instead focuses on his perception that the health care system "has yet to develop institutions for the young and 'medically fragile.'"

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From The New York Times (May 14):

For the Disabled, Age 18 Brings Difficult Choices
By MARC SANTORA

Outside Sam Stabiner’s room pumps the steady drone of ventilators, giving life to his neighbors breath by breath. Most are in their 80s and 90s, in the twilight of their years.

But Mr. Stabiner’s parents never imagined they would have to visit him in a place like this. On the eve of his 21st birthday, he is living in a Manhattan nursing home.

The Stabiners’ predicament, however, is far from unique. As medical advances have allowed patients who might have died as children to survive into adulthood, the patients are falling into a void in a health care system...

...Read more (free registration may be required).


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TAKE ACTION:

Not satisfied with the reality of these segregated lives? TAKE ACTION!

For decades, people with disabilities, both old and young, have wanted alternatives to nursing homes and other institutions when they need long term services. Our long term care system has a heavy institutional bias. Every state that receives Medicaid MUST provide nursing home services, but community based services are optional. Sixty five percent of Medicaid long term care dollars pay for institutional services, while the remaining 25% must cover all the community based waivers, optional programs, etc.

Families are in crisis. When support services are needed there are no real choices in the community. HELP TO CHANGE THIS!

The Community Choice Act (H.R. 1621, S.799) would create equal access to home and community-based services for those eligible for nursing homes.

Since ADAPT's direct actions in D.C. two weeks ago, 15 new House co-sponsors have joined the bill and 1 new co-sponsor in the Senate. Let's keep adding more numbers to both lists!

Please take a minute to urge your Members of Congress to co-sponsor this crucial piece of legislation by clicking on the links below.

• House Action Alert
• Senate Action Alert

UN Treaty on Rights of People with Disabilities Set to Enter into Force!

From the United Nations:

PRESS CONFERENCE ON CONVENTION ON RIGHTS OF PERSONS WITH DISABILITIES

Having received the 20 ratifications required for the landmark Convention on the Rights of Persons with Disabilities to enter into force, the new instrument was now set to take effect on 3 May, Sha Zukang, Under-Secretary-General for Economic and Social Affairs, said at a Headquarters press conference this morning.

Accompanied by the Permanent Representatives of the three countries that ratified the Convention this week -- Maria Fernanda Espinosa (Ecuador), Mohammed al-Allaf (Jordan) and Habib Mansour (Tunisia) -- Mr. Sha said the Convention was not only the first comprehensive human rights treaty of the twenty-first century, it had been negotiated very quickly and would be one of the fastest to enter into force.

Adopted by the General Assembly in December 2006, the Convention seeks to ensure that the world’s 650 million people with disabilities “enjoy the universal human rights that everyone else does in their respective societies”.  One hundred twenty-six countries have signed the instrument and 71 have signed its Optional Protocol, which will allow individuals and groups to petition for relief.

The Convention was deeply rooted in the goals of the United Nations and the Charter vision of a just and peaceful world and better standards of life and larger freedoms, the Under-Secretary-General said.  Through its 50 articles and Optional Protocol, the new treaty aimed to promote and protect the full enjoyment of human rights and fundamental freedoms by all persons with disabilities while promoting respect for their human dignity.

He went on to describe the Convention as a critical entry point for building a society that valued difference and respected the equality of all human beings.  That included ensuring the integration of persons with disabilities into development activities and mainstreaming disability issues into the wider development agenda.  It was now time to commence implementation without delay.

Ms. Espinosa said his country was proud to have become the twentieth nation to ratify the Convention, which reflected its domestic policy and commitment.  Out of Ecuador’s population of 13 million, 1.6 million were disabled and it was the State’s responsibility to ensure their rights and inclusion.  It was no coincidence that Ecuador’s Vice-President was a disabled person.

Noting that her country’s delegation had been very active in the negotiations on the instrument, she said it had presided over the ad hoc group on the drafting of the Convention, which had been open to civil society and interested groups.  As it pursued a national campaign named “ Ecuador without Fences”, the Government sought to transform itself into a country without physical, legal, institutional or mental fences, which would make the inclusion of disabled people a reality.  Among other things, the Government was planning a job-creation project and promoting high-quality education for people with disabilities.

Mr. Al-Allaf said his country emphasized the importance of active participation by people with disabilities and their representative organizations in the drafting, monitoring and implementation of the new treaty, adding that Jordan’s delegation had included experts with disabilities.  Committed to creating a just and equitable society for all persons, Jordan was party to 17 international instruments, including six core human rights treaties.  All Jordanians were accorded equal rights under national legislation, and in 2005, the country had received the Franklin Delano Roosevelt International Disability Award.

Outlining Jordan’s 1993 law on the welfare of disabled persons, he said the National Charter affirmed and enumerated the rights of disabled citizens, including the right to be integrated into society, education, employment and health care.  The new disability law of 2007 had integrated into national legislation the new areas taken from the Convention on the Rights of Persons with Disabilities.  A related national strategy sought to reduce the rate of disability by 5 per cent in its first stage (2007-2009) and 15 per cent in the second (2010-2015), and to enhance the quality of life for disabled persons.  The Convention would help Jordan further develop local policies, review domestic legislation and enrich programmes for the country’s 200,000 people with disabilities.

Mr. Mansour emphasized that the real challenge was implementation -- not only providing help, but giving disabled people a real chance for integration.  Presenting its periodic report on compliance with the International Covenant on Civil and Political Rights to the Human Rights Committee on 18 March, Tunisia had reiterated its determination to advance in the promotion of human rights, a commitment reflected by its ratification of the new Convention.  Tunisia’s policies and strategy were based on solidarity among generations, social groups and persons, a principle that encompassed disability programmes.  It was important to give dignity to persons with disabilities and to provide them with opportunities.  New legislation in place since 2005 provided quotas for persons with disabilities and incentives to strengthen their employability.

Asked to comment on the unwillingness of some countries, including the United States, to sign the Convention on the grounds that their domestic legislation already went beyond the provisions of the new treaty, Mr. Al-Allaf said the Convention was an internationally accepted instrument outlining the principles and defining the mechanisms for States parties to follow.  Accession was important for its universality.

Ms. Espinosa added that, while the decision to sign the Convention or not was a domestic one, it was in the interest of humankind that more countries express their commitment by signing it.

In response to a question about national initiatives to promote the rights of people with disabilities, Mr. Al-Allaf said that, in addition to relevant legislation, his country had established the National Council of Disabled Jordanians, which sought to ensure a high level of mobility, accessibility, equal opportunities and integration of people with disabilities.

Ms. Espinosa said the ratification of the Convention was part of her country’s bilateral and regional agenda to fight discrimination and exclusion.  On the domestic level, Ecuador was going beyond what the Convention required.  There was significant public investment in the creation of jobs and access to high-level education for disabled people, as well as medical and social services.  The Government was also putting in place national programmes that addressed cultural diversity among disabled people.  Ecuador’s legal reforms included measures to bring the Convention into harmony with domestic laws.

Mr. Mansour said that, while his country had been among the first to ratify the new instrument, it had, in fact, been taking important measures to promote the rights of people with disabilities since the end of the 1980s.  Among other things, the Government was creating adequate infrastructure and encouraging telecommuting for people with disabilities.

To several other questions, Ms. Espinosa replied that, once ratified, international conventions became national law in her country.  The domestic legal system needed upgrading to bring it in line with international law.  Ecuador was working on a broad holistic reform, including reform of the social security and employment systems, to build a true welfare State.  Ecuador also had an affirmative-action policy for disabled people.

Mr. Al-Allaf added that his country’s latest legislation had been taken from the Convention and was legally binding.  A 2007 law outlawed discrimination against people with disabilities in the labour market and in wages.

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TAKE ACTION:

...2,497 names and counting. Sign the AAPD petition to President Bush to have the U.S. sign the UN Convention on the Rights of Persons with Disabilities.

...Learn what you can do to build local support for the treaty.

...Find out which presidential candidates support signing and ratifying the Convention.

...Learn more about the Convention at RatifyNow.org.

Co-Sponsors Needed on Bill that Would Freeze Harmful Regs

***ACTION ALERT!!***

Yesterday, Chairman Dingell (MI-15) and Rep. Murphy (PA-18) introduced legislation (H.R. 5613) that would prohibit CMS from implementing seven controversial Medicaid regulations (including limiting CMS payments for targeted case management, rehabilitation services, school-based transportation services for students with disabilities) until April of 2009.

They need our help to get a long, strong list of bipartisan cosponsorship as quickly as possible!

Similar legislation in the Senate is expected very soon.

TAKE ACTION:
Call your Representative during the recess and urge him/her to co-sponsor H.R. 5613 to put a moratorium on the CMS Medicaid regulations until next year.

Look up your Representative online now.

Talking points:

• Please co-sponsor H.R. 5613 to put a freeze on CMS's harmful new Medicaid regulations.
• Without the moratorium and the opportunity it would provide to reevaluate solutions to CMS's concerns, these new regulations will jeopardize the health and safety of Medicaid beneficiaries and limit states' ability to provide access to needed medical, social, educational, and community-based services for people with disabilities in the most effective and efficient manner.

ACTION ALERT - Amendment would add $10 billion to IDEA

***** TIME-SENSITIVE ACTION ALERT *******

Sen. Bernard Sanders of Vermont is submitting an amendment to the Senate Budget Resolution to add $10 billion to the Individuals with Disabilities Education Act (IDEA) as the largest piece of a $32.5 billion redirection of national priorities, paid for by pulling tax cuts on households earning more than $1 million per year.

It's the eleventh hour - the vote on this amendment could come tomorrow.

Take Action:
If you're able, we encourage advocates to call or email your Senators and urge them to vote in favor of the Sanders amendment to increase funding to IDEA.

Find your Senators' contact information.

Parents of "Pillow Angel" Stand by Decision

From CNN:

Parents of disabled child stand by controversial treatment

By Amy Burkholder

NEW YORK (CNN) -- It's been a year since the parents of a severely disabled child made public their decision to submit their daughter to a hysterectomy, breast surgery and drugs to keep the girl forever small. Today, the couple tell CNN, they believe they made the right decision -- one that could have a profound impact on the care of disabled children worldwide.

"The 'Ashley treatment' has been successful in every expected way," Ashley's parents told CNN exclusively in a lengthy e-mail interview. "It has potential to help many others like it helped our precious daughter."

While unwavering in their belief in the treatment, Ashley's parents continue to insist on anonymity. In the year since Ashley's parents went public, not only did the hospital that sterilized Ashley admit it broke Washington state law, but also the doctor who treated Ashley committed suicide...

...Read more.

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More on Ashley:

• Picture album from Ashley's parents' website
• Ashley's parents' blog
• Experience of another "Pillow Angel" - "Been there. Done that. Preferred to grow."

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ACTION ALERT

From F.R.I.D.A:

The struggle continues!  Want to do something about it???  FRIDA has some action requests for you.

 

First and most importantly, contact Dr. Nancy A. Murphy in Utah to let her know that you think the medical intervention in the case of Ashley X was WRONG.  Tell her that instead of Ashley's parents changing her body, they should have sought out community supports and assistive technology.  People with disabilities around the world agree that society should change to us---we should not have to be "fixed" for society.  Dr. Murphy is the chair of the American Academy of Pediatrics Committee on Children with Disabilities and she plans to talk about the Ashley X case with the committee at the AAP conference in October. We must help Dr. Murphy understand the disability rights position on this issue.  Contact her and explain what you think---she seems to be trying to stay objective and get the issue resolved in the medical community, but it will help if she hears from us.  If we do not, who will?  In 2007, over 90 disability rights groups expressed opposition to what happened to Ashley!  You can email Dr. Murphy or call her at 801-581-9978.  You can also call her assistant, Erin Wachs at (801) 581-9978.  Read Dr. Murphy's bio.

 

Please contact Art Caplan in Philadelphia and thank him for supporting community choice options in the CNN Ashley X article. Email him or call him at (215) 898-7136.  Philly ADAPT had to chase Dr. Caplan down in a hallway to get him to commit to supporting community choice.  He is keeping that promise.  He is on CNN quite often as their expert on bioethics.

 

Finally, please comment on the story above at the CNN website by scrolling down to the bottom.  Let CNN know what you think!  We need disability rights perspectives on there!  There are a LOT of comments supporting the parents' decision to intervene on their daughter's body. 

 

Please take some time in the next couple of days to contact these people and protect all our rights to control over our own bodies.  Go go go!

 

Thank you,

 

FRIDA

Join ADAPT Coalition Letter to Oppose Harmful CMS Case Management Rules

ACTION ALERT!

Interim Final Rules issued by the Centers for Medicare and Medicaid Services (CMS) will reduce federal case management reimbursement targeted for transitioning people from institutional settings to the community.  Under the Interim Final Rules, CMS reduces the funding for individuals "transitioning to a community setting" from the current 180 days to only 60 days if the individual has been institutionalized for six months or more.  CMS will only allow payment for 14 days if the individual has been institutionalized for less than six months.  This change undercuts efforts at the state level to comply with the Olmstead decision, implement the Money Follows the Person Demonstration programs and support people transitioning into the community from institutional placement. 

We must let CMS know that we oppose this change. 

National ADAPT is organizing a coalition response to show the widespread opposition for this change.  If you would like to add your organization’s name to this letter, email Linda Taylor at LTaylor@rochestercdr.org and we will add you.  The deadline to respond to CMS is February 4th, so please respond to Linda before 5 pm EST on February 1st.


COALITION LETTER TO CMS OPPOSING CASE MANAGEMENT CHANGES


January 22, 2008
Dennis Smith, Director of the Center for Medicaid and State Operations
Department of Health and Human Services
Attention CMS-2237-IFC
P.O. Box 8016
Baltimore, MD 21244-8016

Re: Interim Final Rule on Case Management Services

Dear Mr. Smith:

The undersigned organizations are deeply concerned about and oppose Interim Final Rules issued by the Centers for Medicare and Medicaid Services (CMS) which will reduce federal case management reimbursement targeted for assistance transitioning individuals from an institutional setting to the community.  Under the Interim Final Rules, CMS would reduce the funding for such an individual from the current 180 days to only 60 days if the individual has been institutionalized for six months or more.  CMS would only allow payment for 14 days if the individual has been institutionalized for less than six months.

CMS staff stated that the rationale for this change, in part, is that payment for transition case management is a duplication of payment to the institution which is expected to provide “discharge planning”.  We strongly disagree with this assertion.  Transition into the community requires a great deal of work to coordinate the services and supports individuals need to be successful.   Based on the collective experience of advocates and service providers in our coalition, we know that institution-based staff is unfamiliar with the complex array of community-based housing options, services, and supports that must be navigated to transition into community living.  This work is particularly difficult and time-consuming because the entire plan must be in place at the same time.   It is impossible to effectively put one component of a plan in place and then work on another piece. 

CMS originally changed these case management rules and increased the allowable payment to address concerns that people needed additional support beyond institutional discharge planning to transition to community living.  This change was made to help states comply with the Olmstead decision.  Reversing this position simply strengthens the institutional bias and undercuts state transition efforts.  The timing on this change is particularly devastating because states are beginning to implement their Money Follows the Person Demonstration programs.  Advocates have been working with the states to use the expanded case management funding to support the work needed to make community living a viable alternative.  More importantly, this funding stream would help transition people into the community long after the demonstration program was over.

We are also concerned that the payment system creates a huge disincentive for smaller non-profit organizations to do this work.  Payment is made only after the individual has transitioned to the community.  Smaller non-profit organizations, which have been the leaders in transitioning people out of nursing facilities, often do not have sufficient cash flow to support the work while they wait months for payment.  We urge CMS to work with advocates to develop an approach which maintains accountability for the work but also addresses this concern.

Again, we urge you to retract these devastating changes.

Sincerely,

Tell CMS 60 Days for Community Transitioning Isn't Enough!

This action alert comes to us from Steve Gold:

***ACTION ALERT***

Medicaid's Targeted Case Management -
Information Bulletin #232

BACKGROUND:
Forty-one States in FY 2006 received substantial
Medicaid funds (from $10 m up to $419m per year) for MA's "Targeted Case Management" services.

On July 25, 2000, the U.S. Department of Health and Human Services' Center for Medicare and Medicaid Services wrote that Targeted Case management services could be provided "to institutionalized persons who are about to leave the institution, to facilitate the process of transition to community services."

CMS wrote that these services could be used "to enable the person to gain access to needed medical, social, educational and other services in the community," including housing, rental subsidies, personal attendant care services.  CMS noted that it was encouraging States to use these services in response to the Supreme Court's Olmstead decision.

CMS told your State that Medicaid's federal reimbursement for Targeted Case Management
services "may be furnished during the last 180 consecutive days of a medicaid eligible person's
institutional stay, if [the Targeted Case Management services were] provided for the purpose of community transition."

Put simply, States received federal reimbursement for the case management work it provided to persons in nursing homes and other institutions while these persons were still in the institution and were making all the necessary preparations to move back to the community.

We know that it takes quite a bit of time to transition people from institutions to the community.  People often must obtain identification papers (a birth certificate, divers' license, baptism papers), apply for community benefits (food stamps, paratransit eligibility), make applications for affordable, accessible, integrated housing (whether public housing, vouchers, or other housing), as well as obtain appropriate durable medical equipment (many may need a motorized wheelchair which the nursing facility or other institution frequently did not provide).

CMS has issued an "Interim Final Rule" which will limit federal reimbursement for "transitioning to a community setting" to 60 days from the current 180 days. CMS has offered no explanation for the reduction and offered no examples of States' abusing the 180 days or any other reason for the reduction.

While it would be terrific if all the work could be accomplished in 60 days and the person transitioned to the community within 60 days, we all know that in many cases that is not possible. Even CMS does not respond to inquiries regarding SSDI or Medicare within 60 days!

TAKE ACTION!
Please write to the Department of Health and Human Services and let Secretary Michael O. Leavitt hear your concern.

Don't delay.  This must be done ASAP.

This CMS rule was issued on 12/4/07 and the comment period ends on 2/8/08.  You must have your comments in by 2/8/08.

1.  You can electronically submit comments to
http://www.cms.hhs.gov/eRulemaking
Click on the link "submit electronic comments on CMS regulations with an open comment period."  Use Word format. 

Remember to cite correct CMS file number.

2. Or by regular mail to:
    Department of Health and Human Services
    Attention CMS -2237 -IFC.
    P.O.Box 8016
    Baltimore, MD 21244-8016
    Re: Case Management Services' Interim Final Rule"

Please use the correct CMS file number. 

Read the entire Interim Rule.

~Steve Gold, The Disability Odyssey continues