Comment on FR Doc # 2026-10134

Thank you for the opportunity to provide feedback on the proposal to remove the reporting requirement for Comparable Benefits. While Michigan Rehabilitation Services (MRS) understands the challenges RSA faces with inconsistent or invalid data, MRS is concerned that eliminating this requirement would weaken an important accountability tool within the vocational rehabilitation (VR) program. Comparable Benefits are integral to the VR process, and regulations such as 34 CFR § 361.46 and § 361.53 place clear emphasis on identifying, reviewing, and coordinating these benefits as part of the IPE and service delivery. Without a reporting mechanism, it becomes more difficult for VR agencies to demonstrate consistent compliance with these longstanding regulatory obligations. MRS is also concerned about the fiscal impact. Comparable Benefits function as a safeguard to ensure that other responsible public entities provide or pay for services before VR funds are used. Removing the reporting requirement reduces transparency around how effectively these determinations are being made, which could increase unnecessary VR expenditures and reduce interagency accountability. Additionally, at a time when the federal administration has placed heightened emphasis on preventing fraud, waste, and abuse, eliminating a key oversight and documentation requirement feels counterintuitive. For these reasons, MRS opposes removing the Comparable Benefits reporting requirement and encourages RSA to instead strengthen guidance and support to improve data quality while maintaining the reporting requirement.