Public Comments

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MEMORANDUM
To:

From:
Date:
Re:

Hon. Robert F. Kennedy, Jr., Secretary of Health and Human Services
Hon. Mehmet Oz, MD, Administrator, Centers for Medicare and Medicaid
Services
Andrew Langer, President, Main Street Foundation
May 18, 2026
Comments on the Department of Health and Human Services Centers for
Medicare and Medicaid Services Information Collection Request, “Good
Cause Processes (CMS-10544),” Docket #CMS-2026-1090, Fed. Reg. 202605217, Published March 16, 2026

Below are comments of the Main Street Foundation’s Center for Regulatory Analysis and
Engagement (CRAE) in response to the Department of Health and Human Services Centers for
Medicare and Medicaid Services Information Collection Request, “Good Cause Processes
(CMS-10544),” Docket #CMS-2026-1090, Fed. Reg. 2026-05217, published March 16, 2026.
CRAE is a project of the Main Street Foundation, a recently-formed non-profit, non-partisan
501(c)(3) research and education foundation. Our mission is to bring a disciplined, commonsense perspective to the regulatory process, one grounded in real-world experience, sound
science, and rigorous economic analysis. We work to ensure that the costs, risks, and benefits of
regulatory proposals are evaluated transparently and accurately, and that the voices, interests,
and freedoms of Americans, particularly small businesses and working families, are
meaningfully represented in regulatory debates. Above all, we focus on outcomes: regulations
should address real problems, function effectively in practice, and improve conditions on the
ground—not exacerbate the challenges they are intended to solve.
The Center for Regulatory Analysis and Engagement (“CRAE”), a project of the Main Street
Foundation, appreciates the opportunity to comment on CMS’s proposed reinstatement without
change of the information collection associated with “Good Cause Processes,” CMS–10544. The
good-cause reinstatement framework serves an important role in preserving continuity of
coverage for Medicare Advantage and Part D beneficiaries who experience temporary
disruptions caused by circumstances outside their control. Maintaining a workable and

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administrable reinstatement pathway helps support both patient stability and broader program
integrity.
The underlying statutory and regulatory framework appropriately recognizes that beneficiaries
may encounter unforeseen events that impair their ability to make timely premium payments.
Unexpected hospitalization, medical emergencies, cognitive impairment, caregiver disruption,
natural disasters, or other temporary crises may interfere with routine administrative obligations
even where beneficiaries fully intend to maintain coverage. A properly functioning good-cause
process helps ensure that inadvertent lapses do not unnecessarily disrupt access to care,
prescription drugs, or ongoing treatment relationships.
The continuation of these protections is particularly important given the demographic
characteristics of many affected beneficiaries. Medicare populations frequently include
individuals managing chronic illness, disability, limited mobility, or complex medication
regimens. Administrative disruptions that result in loss of coverage may impose downstream
consequences that extend well beyond temporary enrollment status, including treatment
interruptions, medication nonadherence, and increased healthcare instability. CMS is therefore
correct to preserve mechanisms that allow for equitable reinstatement where good cause exists.
At the same time, the Paperwork Reduction Act appropriately requires agencies to ensure that
information collections remain necessary, practical, and proportionate to their intended
objectives. The collection associated with good-cause reinstatement should remain narrowly
tailored to obtaining only the information reasonably necessary to evaluate eligibility for
reinstatement. CMS should continue emphasizing practical utility and burden minimization when
overseeing implementation of these requirements by plans and administrative contractors.
CRAE encourages CMS to remain attentive to the risk that documentation requirements may
become unnecessarily complex or difficult for vulnerable beneficiaries to satisfy. Individuals
seeking reinstatement are often doing so during periods of medical, financial, or personal
instability. Excessively rigid evidentiary expectations, duplicative requests for records, or
unclear submission standards may inadvertently transform the process from a safeguard into an
administrative barrier. The good-cause framework functions most effectively when it remains
accessible, understandable, and operationally realistic.
Similarly, CMS should continue working to ensure that Medicare Advantage organizations and
Part D sponsors apply reinstatement standards consistently and transparently. Significant
variation in documentation expectations, review timelines, or procedural requirements across
plans may create confusion for beneficiaries and increase administrative burdens for all parties
involved. Greater standardization can improve predictability, reduce unnecessary appeals or
disputes, and strengthen confidence in the fairness of the reinstatement process.
CMS should also continue encouraging the use of modernized and flexible submission
mechanisms where feasible. Beneficiaries and caregivers should be permitted to provide
supporting documentation electronically, telephonically, or through other administratively
efficient methods when appropriate. Allowing multiple submission pathways can reduce delays,
improve accessibility, and minimize avoidable paperwork burdens while still preserving
adequate program oversight and documentation integrity.

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In addition, CMS should remain attentive to the cumulative burden imposed on healthcare
providers, caregivers, and family members who may assist beneficiaries during reinstatement
requests. Providers and caregivers are frequently asked to supply supporting information during
periods of medical urgency or operational strain. Information requests should therefore remain
proportional and limited to materials directly relevant to evaluating the existence of good cause.
CRAE further encourages CMS to periodically review whether the existing burden estimates
accurately reflect real-world administrative experience. Information collections that appear
manageable on paper may, in practice, require substantially greater time, coordination, or followup activity for beneficiaries and plans alike. Continued monitoring of operational outcomes can
help CMS identify opportunities to streamline procedures, improve clarity, and reduce
unnecessary administrative friction over time.
Thank you again for the opportunity to comment on this proposed information collection. CRAE
supports the continuation of appropriately tailored good-cause reinstatement protections that
preserve continuity of coverage while minimizing unnecessary administrative burden. Durable
Medicare administrative policy depends not merely on maintaining procedural safeguards, but on
ensuring that those safeguards remain transparent, proportionate, administrable, and realistically
accessible to the beneficiaries they are intended to protect.
Sincerely,

Andrew M. Langer
President
Main Street Foundation

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