Comment from ACHIEVE Human Services, Inc.
ACHIEVE Human Services, Inc.OpposeAdvocacy
Summary: ACHIEVE Human Services, Inc. argues that the proposed rule lacks transparency regarding CNA fee calculations and suggests a more analytical, risk-based, and tiered pricing structure. They also express concern that the 25% subcontracting threshold and associated compliance requirements impose an administrative burden and may limit the ability of NPAs to enter new lines of business.
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