Comment on CMS-2026-2279-0001
David RochaSupportIndividual
Summary: The commenter supports the proposed action but argues that it should be expanded to include subcontractual relationships and delegation. They specifically request that CMS classify these relationships as first-tier FHIR execution actors.
Medicaid managed care quality should go not only to the delegated and downstream entities, but also to the subcontractual relationships and delegation.
CMS needs to classify subcontractual relationships and delegation as first tier FHIR execution actors.
42 CFR 438.230 Subcontractual relationships and delegation
https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-438/subpart-D/section-438.230