CMS recently published a proposal that could significantly change the future RHC recertification process. The proposal would allow clinics to complete a self-attestation process in place of routine periodic on-site recertification surveys currently performed through State Survey Agencies.
While this proposal has not been finalized, it is important that clinics do not interpret these discussions as a reduction in compliance expectations or oversight responsibilities.
RHCs remain responsible for maintaining continuous compliance with all Conditions for Certification — regardless of how often surveys occur or what future processes may look like.
HSA strongly encourages clinics to continue:
Routine compliance reviews and mock surveys
Policy and procedure updates
Staff education and competency training
Quality assurance and risk assessment activities
Ongoing operational and documentation oversight
Compliance is about far more than preparing for a survey. Strong compliance programs help protect patient safety, improve quality of care, reduce operational risk, and strengthen the long-term stability of Rural Health Clinics.
Our team has seen firsthand how serious compliance concerns can go unidentified for years without proactive oversight. Maintaining strong internal processes remains critical, regardless of potential survey changes.
HSA is here to help. Our experts can assist clinics in evaluating and strengthening their compliance efforts through:
RHC mock surveys
Compliance assessments
Staff education and training
Policy and procedure review
Emergency preparedness support
Corrective action planning and ongoing guidance
You can review the CMS proposal HERE.
We will continue monitoring developments closely and provide updates as additional guidance becomes available. If you have any questions, HSA is here for you. You can contact us at any time at 231.924.0244 or email us.
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