Comment on CMS-2026-2047-0002

Summary: VibezBombz, a behavioral health engagement organization, supports the proposed action but argues that the current implementation plan lacks a viable way to verify functional impairment for individuals with substance use disorders or mental illnesses. They urge CMS to recognize non-clinical, peer-delivered functional-capacity attestations as an acceptable verification method to ensure these populations are not procedurally disenrolled.