Comment on CMS-2026-1454-0001

The proposal to replace mandatory on-site recertification surveys with a six-year self-attestation cycle for Rural Health Clinics and related facilities prioritizes administrative convenience over the tangible verification of patient safety. While the stated goal of reducing regulatory burden is understandable, relying solely on self-reported compliance creates a dangerous gap where critical deficiencies in infection control, quality, staffing ratios, and equipment maintenance can go undetected for years. Paperwork cannot capture the reality of a clinical environment; only a physical presence can verify that the standards promised on a form are actually being practiced at the bedside, particularly in rural communities where these facilities often serve as the sole lifeline for vulnerable populations. However, acknowledging that the cost and disruption of frequent surveys can be a genuine strain on small providers, we suggest a middle ground that preserves safety without ignoring fiscal realities. Rather than eliminating on-site visits entirely, CMS could implement a risk-based survey model or offer subsidies for survey costs for qualifying rural clinics, perhaps funded by the savings realized from reduced administrative overhead. This approach would maintain the essential "boots on the ground" verification that ensures public trust and patient safety, while still addressing the financial burdens that prompted this proposal. Ultimately, no amount of cost-saving justification should supersede the fundamental requirement that healthcare compliance be observed, not just asserted.