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 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.

Elsie B. Crawford, an RN, opposes replacing on-site recertification surveys with a self-attestation model for Rural Health Clinics. She argues that independent oversight is essential for patient safety and regulatory integrity, particularly in rural areas, and suggests refining existing survey processes instead of removing them.

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.