private organizations, the NHRC believes that the government has failed to
actively push clinics (the institutions that have the closest connection to the needs,
rights, and interest of persons with disabilities seeking medical treatment) to fully
comply with accessibility regulations. Although the MOHW set benchmarks for
rewards in the Guidelines for the Administration and Issuance of Retention Funds
Ensure Basic Level Western Medicine Quality Assurance to encourage clinics to
build accessible medical environments, their effectiveness is limited. For
example, as of June 1, 2021, only 30% of all clinics had accessible or patientfriendly medical environments. Additionally, the data were reported by the clinics
themselves, making their accuracy and whether the clinics complied with
accessible building design guidelines indeterminate. The government has long
ignored the obstacles faced by persons with disabilities seeking medical
treatment, and has not yet set concrete goals and schedules, resulting in persons
with disabilities having to go to large hospitals (as opposed to having a choice
between clinics and hospitals) if they wish to receive favorable medical treatment.
The NHRC recommends that instead of passively waiting for basic clinics to
submit an application for a reward, the government should categorize elementary
clinics into different divisions according to the results of demand surveys and set
specific goals accordingly. Today, among MOHW-affiliated hospitals, there
remain four whose online registration systems do not have special options to
assist persons with visual or hearing impairments. The MOHW’s response letter
and explanations99 provided in discussions revealed that it has no intention or
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objections made by groups such as medical associations and clinics’ associations. The department’s
failure to send anyone to the meeting or to express its own opinions was equivalent to it forfeiting
its right as a competent authority. Furthermore, an investigation of the objections made by the
aforesaid groups showed that their objections contained many errors which the MOHW did not
proactively communicate.
ii. The MOHW and competent authorities of the relevant industries were unfamiliar with accessible
environment regulations and failed to propose solutions to solve the problems raised by businesses.
The former simply set aside the problems raised, thus setting back the scheduling for related units
to review the incorporation of clinics into accessible environment regulations.
In a response letter to the NHRC, the MOHW stated the following: The MOHW had already issued
letters in October 2015 informing the indicated MOHW-affiliated hospitals to handle the
aforementioned problems and, in a 2016 meeting, discussed and resolved to comply with relevant
policies to build online registration systems for persons with disabilities and modify the template
functions of the current official online registrations for persons with disabilities. Resolutions
pertaining to the content of the special options were also made in the meeting that hospitals should
purchase special options based on their needs. During discussion, the MOHW indicated the following
reasons why special options for persons with visual or hearing impairments were not in place: (a)
Local residents generally made reservations by phone. (b) Some of the MOHW-affiliated hospitals
were small hospitals. (c) Some of the MOHW-affiliated hospitals assessed the need for such options
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