July 28, 2023

ACR Comments on Proposed Table Height Standards for Medical Diagnostic Equipment

The American College of Radiology® (ACR®) submitted comments in response to a notice of proposed rulemaking (NPRM) that proposes table height standards intended to allow persons with disabilities maximum independence in accessing related medical diagnostic equipment (MDE).   

The Architectural and Transportation Barriers Compliance Board was tasked to establish standards per a provision in the Patient Protection and Affordable Care Act that requires it to develop minimum technical criteria for medical diagnostic equipment used in or in conjunction with physician offices, clinics, emergency rooms, hospitals and other medical settings. The provisions specified that the standards “shall ensure that such equipment is accessible to, and usable by, individuals with accessibility needs, and shall allow independent entry to, use of, and exit from the equipment by such individuals to the maximum extent possible.” 

The College provided extensive input that highlighted the importance of ensuring appropriate access to diagnostic equipment for all patients, and raised concerns that the proposed standard represents a ‘one size fits all’ approach to diagnostic equipment table height that does not reflect the diversity in design and purpose, engineering complexities, or clinical practices applicable to diagnostic imaging equipment.  

As issued by the Board, the proposed standards will not be mandatory for healthcare providers and equipment manufacturers. In the future, agencies or entities may choose to issue regulations or adopt policies requiring healthcare providers to acquire accessible medical diagnostic equipment that complies with the technical criteria set forth by the Access Board. However, these agencies or entities would have to develop the appropriate scoping provisions to determine how to apply these technical criteria and would be free to strengthen or lessen the requirements as they so determine.

For more information, contact Gloria Romanelli, ACR Senior Director, Legislative and Regulatory Relations, Legal Counsel, Quality and Safety.