HHS and DOJ issued final rulings in 2024 that adopt the ADA Access Board’s 2017 MDE standards as enforceable requirements. Any facility receiving federal funding (including Medicare, Medicaid, and CHIP) and any government facility must comply with the requirements by July and August 2026, respectively.
Looking Back at the ADA in Action
The Americans with Disabilities Act of 1990 (ADA) outlines federal civil rights laws prohibiting discrimination against individuals with disabilities in everyday activities, including equal access to medical services.
The 2010 Patient Protection and Affordable Care Act (ACA) required that the U.S. Access Board promulgate standards for medical diagnostic equipment (MDE) to provide accessible independent transfer from a wheeled mobility device to the examination table or chair. And while the ACA also specifies that the U.S. Access Board is responsible for developing the accessibility standards, it does not grant the Access Board enforcement authority. Instead, the ACA designates that enforcement of these standards is the responsibility of other federal agencies, such as the Department of Health and Human Services (HHS) and the Department of Justice (DOJ).
In 2012, the U.S. Access Board formed an advisory committee to help determine the MDE standards. The advisory committee brought together diverse stakeholders, including disability rights advocates, healthcare professionals, manufacturers, and technical experts, to ensure that the resulting standards would address the needs of individuals with disabilities effectively.
In January 2017, the Access Board added part 1195 to title 36 of the Code of Federal Regulations. This new regulation addresses the accessibility standards for medical diagnostic equipment (MDE) as required by the ACA. The U.S. Department of Veterans Affairs announced in April of 2017 that they would adopt the new standards even though, at the time, they were not enforceable by an enforcing agency.
Medical diagnostic equipment (MDE) standards aim to provide physical configuration and operational characteristics of accessible examination tables and chairs so that medical and dental facilities can properly provide accessible care to individuals with disabilities. Patient seating equipment falls into one of these categories:
- M301 – Diagnostic Equipment Used by Patients in Supine, Prone, or Side-Lying Position such as GYN and OB, categorized as an M301 examination table.
- M302 – Diagnostic Equipment Used by Patients in a Seated Position such as ENT, Podiatry, Dermatology, Plastic Surgery, Ophthalmology, Oral Surgery, and others, categorized as an M302 examination chair.
The regulations below specify the physical requirements of M301 and M302 equipment.
Breaking Down HHS and DOJ Enforceable Regulations
MTI has taken the time to analyze and understand the recent rulings from HHS and DOJ and has outlined the key equipment requirements facilities will be held accountable to.
- 17″-19″ Entry Height A low transfer adjustable height of 17″-19″ and a high transfer height of at least 25″ for M301 and M302 equipment is required. Entry height should be 17″-19″ from the floor to the highest point of the transfer surface, including bolsters, with the upholstery in an “uncompressed” (relaxed) condition.
- 21″x17″ Transfer Surface M302 examination chairs must have a transfer surface at least 21″ wide and 17″ deep, while M301 examination tables must have a transfer surface of at least 28” wide and 17” deep. Examination chairs and tables must have the ability for transfer on two adjoining sides (front and side) of the transfer surface. However, there is an exception for M302 chairs that permits transfer from a mobility device onto opposing sides of the transfer surface when a fixed footrest obstructs the transfer surface, such as ENT, Dental, and Podiatry chairs.
- Transfer Support A transfer support must be used to ensure patient safety and stability during the transfer process. The transfer support must meet specific length, size, and spacing requirements. The cross-sectional dimensions of the transfer support are also specified to ensure patients can get a firm grip. Armrests do not qualify as a transfer support.
- Leg Supports Medical chairs should provide secure and adjustable leg supports to accommodate patients who require stabilization or support during procedures or procedures that use stirrups. While the ADA Standards do not specify exact requirements for leg support, the Department of Justice guidelines emphasize that accessible medical equipment must accommodate individuals with varying levels of mobility and physical support needs.
- Unobstructed and Clear Floor Space Chair installation and use is also a part of being compliant. Clear floor space of at least 30 inches by 48 inches must be provided adjacent to the equipment to allow for easy wheelchair access.
MTI Advances Chair and Table Technology Meeting ADA Compliance Standards
MTI’s efforts to incorporate ADA compliance standards into its products have led to breakthroughs in specialty exam room chair and table technology and engineering. Many of MTI’s breakthroughs are patented technologies, designed to enhance accessibility and compliance with ADA standards.
- Achieving 17-19” entry height for standard, swivel, and mobile base styles
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- Intelligent, retractable motorized footrest to achieve <19” height – Patent #10,632,037 & continuation 10,898,402
- Compact swivel base with motorized locking mechanism – Patent #10,632,037 & continuation 10,898,402 – ADA compliant, one-touch swivel locking.
- Compact “Low Boy” mobile base with fully functional steering casters
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- SmartTech™ / Smart Safety™ intelligence preventing impacts
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- Not only prevents collisions but also simplifies moving the chair into a safe position to accommodate the desired access.
- Constantly tracks the position of each actuator and calculates interference that would compromise safety of the patient or caregiver.
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- ComfortSync™
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- Footrest on 463/464 supports patients’ feet at 90 degrees, even while the foot section angle is raised – so the patient does not feel like they are sliding out of the chair once the back section begins to recline.
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- Soft Start and Stop Technology
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- Smoothly moves patients from position to position for a more comfortable experience.
Because MTI has been committed to manufacturing exam chairs that meet ADA compliant standards longer than most competitors, facilities can be assured that when purchasing one of MTI’s specialty-specific chairs, it will not only meet the necessary requirements but will also improve the care experience for patients and caregivers alike.
Additional information about recent ADA changes can be found at mti.net/ada.
An MTI Solutions Advisor can also provide further assistance in discussing specific scenarios and needs.
