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Commenting April 12 on a proposed rule to strengthen oversight of accrediting organizations, AHA told the Centers for Medicare & Medicaid Services it supports requiring accrediting organizations to use Medicare’s Conditions of Participation and Conditions for Coverage as their minimum accreditation standards, and to provide an explicit crosswalk of their standards with relevant Medicare regulations. However, AHA recommended that CMS allow accrediting organizations to retain a limited number of “black-out” dates for accreditation surveys and provide same-day notice of the pending arrival of on-site surveyors. It also said CMS should transition to a direct observation approach for validation surveys; modify an “overly punitive” proposal to remove the deemed status of providers following certain validation surveys; clarify when the agency would make survey reports public; and eliminate duplicative complaint surveys.