Comment on CMS-2026-1454-0001

I appreciate CMS’s intent to modernize the certification and recertification process for providers and suppliers, including Rural Health Clinics (RHCs). However, I strongly oppose the proposal to replace recertification surveys with a self-attestation model. From a policy and patient safety standpoint, independent, on-site surveys are a foundational component of the regulatory framework that ensures compliance with Medicare Conditions of Participation. Eliminating or substantially reducing this external oversight introduces significant and unnecessary risk to patient care, particularly in rural and underserved communities where access to high-quality healthcare is already fragile. Self-attestation, while administratively appealing, does not provide the same level of rigor, objectivity, or accountability as on-site surveys conducted by trained surveyors. Regulatory compliance is not solely a documentation exercise, it requires validation of real-world practices, workflows, and patient care delivery. Unannounced surveys are especially critical, as they offer an accurate assessment of day-to-day operations rather than a curated representation prepared for review. Of particular concern is the increased risk associated with larger healthcare organizations and corporate entities operating RHCs. In the absence of routine, independent surveys, there is a heightened likelihood that financial pressures, operational efficiencies, or competing organizational priorities could result in inconsistent adherence to regulatory standards. Self-attestation models inherently rely on internal reporting structures, which may not always fully capture deficiencies or may deprioritize compliance in favor of other business objectives. Without external validation: •Variability in compliance across organizations is likely to increase •Gaps in patient safety practices will go undetected •Standardization of care and adherence to federal requirements will erode over time •Public trust in the integrity of the Medicare-certified provider system will be compromised Maintaining a robust survey process is particularly critical for protecting vulnerable rural populations, who often rely on RHCs as their primary access point for care. These patients deserve the assurance that their providers are consistently meeting established safety and quality standards, verified through impartial evaluation. While administrative burden is a legitimate consideration, it must not outweigh the fundamental responsibility to ensure safe, high-quality patient care. The solution should not be the removal of oversight, but rather the refinement of existing survey processes. CMS could pursue targeted improvements such as risk-based survey frequency adjustments, enhanced coordination with providers, or streamlined documentation expectations, while preserving the essential role of independent review. Strong regulatory oversight is not optional; it is a cornerstone of patient protection and program integrity. Replacing survey-based recertification with self-attestation would weaken this framework and introduce preventable risks into the healthcare system. I strongly urge CMS to retain the current survey-based recertification requirements for Rural Health Clinics and to prioritize patient safety, accountability, and regulatory consistency in any modernization efforts. Respectfully submitted, Tawnya Brock