Self-Attestation for Recertification of CORFs, OPT/SLP, and RHCs Providers and PXR Suppliers (CMS-10952A-D)

The Compliance Team (TCT), a healthcare accreditation organization, opposes the proposal to replace physical surveys with self-attestation for RHCs, OPT/SLP, and PXR providers. They argue that eliminating onsite surveys undermines statutory requirements, compromises patient safety, and increases the risk of undetected fraud and abuse. Instead, they suggest expanding the use of accredited deemed status to maintain independent oversight while reducing the burden on State Survey Agencies.

QUAD A, an accreditation organization, opposes the proposal because it may weaken oversight and compromise patient safety by reducing timely on-site surveys for Rural Health Clinics (RHCs) and Outpatient Physical Therapy (OPT) providers. They argue that attestation is not a substitute for physical inspections and urge CMS to maintain a proactive, on-site survey presence to ensure compliance and prevent "operational drift."

The National Rural Health Association (NRHA) opposes transitioning from in-person surveys to a self-attestation process for rural health clinics (RHCs), arguing that in-person surveys are a critical tool for accountability and patient safety. Instead of removing these surveys, the NRHA suggests that CMS should focus on reducing administrative burdens through specific regulatory clarifications regarding behavioral health, telehealth payment parity, and scope of practice rules.

The National Association of Rural Health Clinics (NARHC) opposes switching to a self-attestation model for Rural Health Clinics (RHCs) because they believe it would decrease program compliance and remove the "culture of accountability" provided by in-person surveys. Instead, the organization argues that CMS should reduce administrative burdens by modifying outdated regulations—such as the behavioral health service threshold and scope of practice rules—and by updating key guidance documents like Appendix G.

Richard Hillyer, a physical therapist and experienced compliance surveyor, opposes the proposal to replace regular surveys with a six-year self-attestation. He argues that self-attestations are inadequate for ensuring patient safety and program integrity, noting that many administrators are unaware of specific compliance requirements and that on-site inspections are necessary to verify the quality of care.

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.

The commenter argues that allowing Rural Health Clinics and Outpatient Physical Therapy providers to self-attest compliance every six years instead of undergoing regular on-site surveys poses a significant risk to patient safety. They contend that independent oversight is necessary to ensure adherence to safety protocols and to maintain a culture of continuous quality improvement.

The commenter, representing a perspective focused on rural healthcare, opposes the proposal to allow self-attestation for RHC recertification. They argue that self-attestation reduces oversight and threatens patient safety in underserved areas, advocating instead for continued triennial onsite surveys to validate safety practices.

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.

The commenter opposes replacing mandatory on-site recertification surveys with a self-attestation cycle, arguing that it compromises patient safety and fails to verify actual clinical standards. They suggest a middle ground involving a risk-based survey model or subsidies for rural clinics to balance regulatory oversight with financial constraints.