Comment on CMS-2026-1454-0001

I am concerned that the CMS proposal to allow Rural Health Clinics and Outpatient Physical Therapy providers to self-attest their compliance with Conditions of Participation every six years, rather than undergo regular on-site surveys, raises serious patient safety concerns. On-site surveys are a critical mechanism for ensuring that healthcare facilities consistently adhere to established standards of care. Replacing this process with infrequent self-attestation significantly reduces independent oversight and increases the risk that lapses in compliance will go undetected. Without the objective review provided by in-person surveys, there is a heightened possibility that deficiencies in safety protocols, infection control, and quality assurance will remain unaddressed, potentially placing vulnerable patient populations at greater risk. Furthermore, self-attestation every six years diminishes both transparency and accountability within RHC and OPT settings. Regular surveys not only verify ongoing compliance but also foster a culture of continuous improvement and responsiveness to emerging safety issues. The proposed reduction in oversight mechanisms could inadvertently encourage a “check-the-box” approach to compliance, undermining the robust safeguards that protect patient well-being. In the interest of maintaining high standards of care, I strongly urge CMS to reconsider this proposal and uphold the proven effectiveness of routine on-site surveys as an essential component of patient safety assurance.