Comment on CMS-2026-1454-0001

CMS-10952A-D I am respectfully submitting my comment to express my strong support for the continued requirement of routine surveys for Rural Health Clinics consistent with the position of the National Association of Rural Health Clinics. From direct observation and experience, the need for ongoing regulatory oversight in RHC’s is clear. Many clinics go extended periods between state surveys, and when a survey is ultimately conducted, deficiencies are often identified – sometimes rising to condition level. This pattern underscores the importance of consistent, routine evaluations to ensure sustained compliance and quality of care rather than intermittent correction of issues after long gaps. It is important to note that other CMS-regulated facilities, such as nursing homes, are subject to routine and ongoing inspections. These regular surveys are widely understood to be essential safeguards that protect patient safety and ensure adherence to quality of care standards. The services provided in RHC’s are no less important. As mentioned FQHC's are not subject to routine state survey cycles in the same manner as RHC's, however, Patient Centered Medical Home recognition while optional for FQHCs, has effectively become the norm because federal policy and payment structures strongly incentivize it. That status then requires a survey through an accrediting organization, ensuring ongoing compliance. In contrast, RHC's are not incentivized to obtain that same recognition or similar accreditation, relying instead of periodic surveys to ensure regulatory compliance. From both a professional and consumer perspective, I have observed concerning conditions in many clinic settings. In many cases, the average healthcare consumer may not recognize when a clinic is not following current infection control practices. For example, improperly stored or exposed supplies, use of single does vials on multiple patients, lack of environmental cleanliness, or failure to adhere to accepted sterilization and instrument reprocessing standards may go unnoticed by patients. However, these lapses pose real risks for patient harm. Routine surveys help identify these issues and ensure corrective action is taken. Surveys are not only a compliance mechanism but also an important opportunity for education, reinforcement of best practices, and continuous quality improvement. A self-assessment would not accomplish the needed education, reinforcement and continuous quality improvement. It is also worth considering that, without a requirement for ongoing surveys or accreditation, some organizations may opt to discontinue engagement with accrediting bodies after initial certification, citing cost concerns. However, this could ultimately result in a decline in care quality, as external oversight and guidance play a critical role in maintaining standards and supporting safe patient care. Ultimately, all healthcare settings that provide patient care should be held to consistent and ongoing evaluation. Routine surveys are not simply regulatory requirements—they are essential tools to ensure that patients receive safe, high-quality care, regardless of location. Thank you for allowing the opportunity to comment on this important topic.