Comment on CMS-2026-1454-0001
Lisa SiebertOpposeIndividual
Summary: Lisa Siebert, a registered nurse and surveyor, opposes the move toward self-attestation for recertification. She argues that reduced oversight combined with funding cuts will lead to diminished patient safety, potential fraud, and a decrease in the quality of care provided by RHCs and OPTs.
I wholeheartedly view the potential for diminished quality of care and patient safety is greater with less oversight. Not because the facilities don’t want to provide quality care, but with funding cuts and the design of RHCs and OPTs, and the broad spectrum of care provided, it is already difficult to maintain qualified and credentialed staffing, oversight by Medical Directors, qualtrics measuring and QAPI, reporting, and scheduling and administrative staffing to manage those parts and pieces.
Facilities are already looking for methods to stretch their budgets with the recent and proposed funding cuts to these types of facilities, and unfortunately, staffing and supplies are the first cuts. When a facility does not have the time and the tools to provide safe quality care, and no oversight to monitor compliance, and, also, to provide help and understanding if standards when they need it, the things that fall thru the cracks will directly address patient care. Three-year survey follow-up with facilities should be the minimum, and if anything, more frequent follow-up would help facilities to understand and maintain compliance. Especially with frequent updates and changes to standards.
This doesn’t even address the potential for fraud without frequent enough oversight.
The self-survey process is great if the facilities are dedicating the time to perform them, but there is no guarantee they are being performed as they are designed; to be a full self-survey including policy changes, training, and a plan of correction. And further cuts and less oversight provide a huge opportunity for facilities to place less emphasis on quality care including meeting standards and documentation, and becoming a funnel for shorter visits and higher volume of patient treatment.
I think this would be a detriment to patient quality of care and safety, and to those facilities that work hard to be compliant, and especially to those that don’t or cant maintaincompliance.
Thank you for this opportunity to comment.
Best regards,
Lisa Siebert, RN
QUADA Surveyor