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concerns, such as avoiding the potential negative impact on

a parent’s credit rating, do not apply when a child or

parent is already enrolled in a public insurance or benefits program. Additionally, two commenters who opposed the parental consent requirement when a child or parent is already enrolled in a public benefits or insurance program noted that parents already have the right under Part C of the Act to consent to each and every Part C service on the IFSP and that a separate consent provision provided parents with no additional protections.

A minority of commenters supported proposed

§303.520(a)(1)(i). The primary reasons cited by commenters

for supporting a parental consent requirement when a child or family is already enrolled in a public benefits or insurance program were that: (1) parents should be informed of all potential costs regarding use of their benefits; (2) parents should understand any potential limitations in coverage or future negative consequences and consent ensures accountability; (3) the IDEA Part C consent regulations should align with the IDEA Part B consent regulations; and (4) the consent provisions for public and private insurance should be aligned.

The commenters who expressed concern regarding the potential costs for parents of using public benefits or