Comment on CMS-2026-2047-0002

Summary: The Health Alliance of Northern California (HANC), a regional association of community health centers, opposes several elements of the proposed interim final rule because they create administrative burdens and potential barriers to care for rural populations. They specifically advocate for population-level exclusions rather than individual-level exemptions, broader definitions for seasonal workers, and expanded protections for family caregivers and medically frail individuals.