Comment on CMS-2026-2081-0001

Independence Through Enhancement of Medicare and Medicaid ("ITEM") CoalitionSupportAdvocacy
Summary: The ITEM Coalition, a national consumer- and clinician-led coalition of 103 organizations, urges CMS to preserve the current ACA Essential Health Benefits (EHB) framework. They argue that the current framework is critical for ensuring access to medically necessary assistive devices and technologies, and they oppose any regulatory changes that might weaken these consumer protections or create uncertainty for states and health plans.
On behalf of the Independence Through Enhancement of Medicare and Medicaid (“ITEM”) Coalition membership, we are pleased to submit the attached comments in response to the Centers for Medicare and Medicaid Services (“CMS”) Request for Information (“RFI”) regarding the Affordable Care Act’s (“ACA”) Essential Health Benefits (“EHB”) framework and the statutory requirement that the scope of EHB be equal to the scope of benefits provide under a typical employer plan. For the reasons further illustrated in the attached comment letter, the ITEM Coalition strongly urges CMS to preserve the current EHB framework and reject any regulatory changes that would weaken access to medically necessary medical devices and assistive technologies. Instead, the Agency should use this opportunity to reaffirm that the ACA’s EHB framework is intended to promote innovation, improve functional outcomes, and ensure that individuals with disabilities can benefit from continued advances in medical science and technology.

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