Comment on CMS-2026-1454-0001

Summary: The National Association of Rural Health Clinics (NARHC) opposes switching to a self-attestation model for Rural Health Clinics (RHCs) because they believe it would decrease program compliance and remove the "culture of accountability" provided by in-person surveys. Instead, the organization argues that CMS should reduce administrative burdens by modifying outdated regulations—such as the behavioral health service threshold and scope of practice rules—and by updating key guidance documents like Appendix G.