Comment on CMS-2026-2081-0001

Summary: The Children's Hospital Association (CHA) supports the review of the Essential Health Benefits (EHB) framework but urges CMS to strengthen, rather than narrow, pediatric protections. They argue that "typical employer plans" are insufficient benchmarks for children's needs and recommend using CHIP as a benchmark, establishing clearer federal standards for habilitative services, and ensuring affordability accounts for out-of-pocket costs and access to care.