Comment on CMS-2026-1454-0001
Linda DeubelOpposeIndividual
Summary: The commenter opposes replacing Rural Health Clinic (RHC) recertification surveys with a self-attestation process, arguing that independent surveys are necessary for oversight and patient safety. They suggest that CMS should instead focus on streamlining and improving the efficiency of existing survey processes through collaboration with state and accrediting agencies.
I strongly oppose the proposal to replace Rural Health Clinic (RHC) recertification surveys with a self-attestation process.
Independent recertification surveys provide critical oversight, education, and validation of compliance with federal requirements. This oversight helps ensure that clinics maintain qualified providers and staff, meet regulatory standards, and continue to deliver safe, high-quality care to the communities they serve. Without independent surveys, deficiencies related to patient safety, infection prevention and control, emergency preparedness, and provider compliance are more likely to go undetected, placing both patients and clinics at greater risk.
Rather than implementing self-attestation, CMS should focus on improving survey efficiency by working collaboratively with state survey agencies and accrediting organizations to streamline processes, reduce duplication, standardize workflows, and provide clear, consistent guidance to providers and surveyors. Independent oversight and validation remain essential to maintaining program integrity, ensuring accountability, and protecting the quality of care provided in rural communities.
Thank you for the opportunity to provide these comments.