CMS Final Rule Creates New Restrictions for Accrediting Organizations –Independent Support Remains Essential

On June 12, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Final Rule with comment period, Medicare Program; Strengthening Oversight of Accrediting Organizations (AOs) and Preventing AO Conflicts of Interest, and Related Provisions” (CMS-3367-FC).

This rule introduces significant new requirements for Accrediting Organizations (AOs), including The Joint Commission, DNV, CIHQ, ACHC, and others. Among the key provisions are restrictions on AOs that provide consulting services, including prohibitions against:

  • Providing consultative services prior to an organization’s initial accreditation survey
  • Providing consultative services within 12 months of a reaccreditation survey
  • Providing consultative services in response to complaints received by the AO regarding an accredited organization

The Final Rule also includes additional requirements related to conflicts of interest, oversight of accreditation performance measures, and consistency in survey scoring and standards interpretation. The changes will take effect June 16, 2027

CMS’s Fact Sheet on the Final Rule is available here:

CMS Final Rule Fact Sheet

How Courtemanche & Associates Can Help

Unlike Accrediting Organizations, Courtemanche & Associates operates as an independent healthcare consulting firm and is not subject to these consulting restrictions. Since 1994, we have helped healthcare organizations successfully navigate accreditation, regulatory compliance, and patient safety challenges through our comprehensive consulting and educational services.

Whether you are preparing for an initial survey, maintaining ongoing readiness, responding to regulatory findings, or strengthening your quality and patient safety programs, our experienced team is available to support your organization throughout every stage of the accreditation cycle.

Our services include:

  • Accreditation survey readiness assessments
  • Mock surveys and gap analyses
  • Regulatory compliance consulting
  • Corrective action and resolution support
  • Leadership and staff education
  • Ongoing accreditation and patient safety guidance

Learn more about our services at: Courtemanche & Associates

Contact Us

To learn how Courtemanche & Associates can help your organization meet
today’s evolving regulatory requirements and patient safety expectations, contact
us:

Email: info@courtemanche-assocs.com
Phone: 704-573-4535

Request a Consultation

Talk with our team about compliance, accreditation, or infection control support.

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