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.

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 Instead, the organization argues that CMS should reduce administrative burdens by modifying outdated regulations—such as the behavioral health service threshold and scope of practice rules—and by updating key guidance documents like Appendix G.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.

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.

Meg Portwood, a Nurse Practitioner at Coastal Health Practitioners, supports the proposal to allow self-attestation for RHC recertification. The commenter argues that the current on-site survey process is stressful, disrupts clinic flow, and that the proposed forms sufficiently cover critical program elements.

The commenter opposes the proposed self-attestation for recertification, arguing that routine surveys are essential for ensuring patient safety and quality of care in Rural Health Clinics (RHCs). They contend that self-assessments lack the necessary oversight to identify clinical deficiencies, infection control lapses, and opportunities for continuous quality improvement.

Tawnya Brock opposes the proposal to replace on-site recertification surveys with a self-attestation model for Rural Health Clinics (RHCs). The commenter argues that independent surveys are essential for ensuring patient safety, maintaining regulatory oversight, and preventing compliance gaps, particularly in rural communities.