Re: California’s Bridge to Reform Demonstration (No. 11-W-00193/9)

Executive Summary

There are three major components of the CCI. As drafted, the amendment repeatedly fails to effectively delineate what changes are occurring under each of these separate components. The amendment frequently conflates the three components of the CCI, muddling an already complicated set of changes. The amendment should set forth, in very specific language, which requirements apply to which aspects of the CCI. Our listed concerns illustrate where additional specificity is required.