Comment on CMS-2026-1454-0001

Department of Health and Human Services Centers for Medicare & Medicaid Services re: [Document Identifier: CMS-10952A-D] Honestly we would be thrilled to have a self attestation situation for RHC review; our past on site surveys have been, as alluded to, very stressful and really did not accomplish anything positive as far as clinic care other than eventually with fear and trepidation, being eventually approved. I have reviewed the proposal with our Medical Director and office manager and clinic Nurse Practitioner provider and all are in agreement with "less is better". The forms that are proposed seem to encompass the critical elements of the RHC program; it appears that we can validate what we do in an appropriate manner. Currently we have to constantly be "on edge" re "will the state show up today?" or "when will they show up"?...and what if the management folks are on vacation and clinic staff cannot deal with all the requirements that are asked to verify? We have to routinely do our state PCPCH/Medical home surveys and submit information to the program for ongoing approval; the Federal Motor Carrier Association allows for self study/exam and credentialing, and we have to do facility credentialing for Oregon as well as various insurers, along with provider credentialing on an annual basis and we can do these as a self attestation review which we DO learn from and DO make appropriate changes as required. We actually have ANNUAL RHC review meetings as well as annual Emergency review/or tabletops and feel we are up to date and compliant and keep our notebooks up to date. It would definitely reduce the burden on our RHC if we could just provide patient care without the constant threat of an on site unannounced survey that truly interferes with clinic flow and provision of patient care. Thanks for considering our opinions. Meg Portwood, NP Coastal Health Practitioners in Lincoln City Oregon