In this comment letter APIAHF expresses concerns that a number of the Department of Health and Human Services’ proposed provisions regarding Medicaid and CHIP managed care would reduce or eliminate critical patient and beneficiary safeguards. Such safeguards are essential to the Medicaid and CHIP programs, which by their program design and purpose, serve vulnerable populations who are low-income, may be unfamiliar with the health care system, have low literacy and/or low health literacy and experience a range of factors, including difficulty speaking or reading English, accessing transportation, etc. to maintaining good health and understanding their rights.