Comment on CMS-2026-2047-0002

Summary: The New York Disability Advocates (NYDA), a coalition of provider associations, opposes the interim final rule because it creates administrative barriers that could lead to coverage loss for people with intellectual and developmental disabilities (I/DD). They argue that the rule's reporting and verification requirements are unworkable for medically frail individuals and urge CMS to rescind the rule to protect vulnerable populations from losing essential services.