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1 And we appreciated CMS’ thorough responses to comments for IPAY 2026 and hope the Agency will replicate this for this comment opportunity. These elements were previously highlighted in our comments in response to the IPAY 2026 guidance, and we continue to stress their importance for the 2027 draft guidance.
Timely implementation is particularly critical for beneficiaries requiring immediate mental health or substance use treatment, where delays can lead to worsening health outcomes, increased hospitalization rates, and preventable mortality. 14 National Health Council. link] duals-rfi/.
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