Comments: Accrediting Organizations Conflict of
Interest and Consulting Services; Request for InformationMedicare is a valuable, trusted program that provides health care coverage to over 59 million older adults and people with disabilities. People rely on Medicare for high-quality care and entrust CMS with providing robust oversight that ensures beneficiary health and well-being are always at the forefront.

This reliance and trust can be put at risk if beneficiaries perceive conflicts of interest or bias in the program. We are encouraged that CMS has issued this RFI to determine whether Accrediting Organizations that provide guidance and other consulting to the facilities they accredit could create actual or perceived conflicts of interest. For the reasons outlined below, we conclude these relationships do create a perceived conflict of interest and should be barred.

In order to participate in the Medicare program, most providers—including providers of services, suppliers, facilities, clinics, agencies, or laboratories—must first be certified by State Survey Agencies or accredited by CMS-approved national accreditation organizations (AOs). Most providers may choose between the state agency or the AO at their discretion. However, certain suppliers and laboratories must be accredited by AOs, creating a built-in market for the fee-based accreditation services.