The American Health Care Association/National Center for Assisted Living (AHCA/NCAL) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative, according to Dan Ciolek, associate vice president of therapy advocacy, AHCA/NCAL.

CMS wants more stakeholder feedback on potential policy approaches to strengthen detection, prevention, and enforcement of fraud-waste, and abuse (FWA) across federal healthcare programs.

Ciolek said areas of focus include provider screening, ownership verification, identity proofing, and oversight. He said the request also reflects broader CMS priorities related to FWA, including DMEPOS supplier oversight, AI-assisted coding risks, and beneficiary protection measures.

Of the AHCA/NCAL recommendations, these are the highlights:

• Target fraud-prevention approaches, including AI-based program integrity tools, toward high-risk actors rather than applying broad, one-size-fits-all requirements that impose unnecessary burden on compliant providers;

• Calibrate AI-driven program integrity applications to the unique Medicare/Medicaid patient population characteristics and provider size variance within the long term and post-acute care sector;

• Pursue the least burdensome approaches for information-sharing between CMS, states, and providers to prevent bad actors from entering or remaining the Medicare and Medicaid programs; and

• Ensure appropriate safeguards for both fee-for-service and managed care providers and payers when AI is used, including requiring human oversight and approval of any AI-guided program integrity actions that may affect provider enrollment, audit targeting, or automated denials.

Comments or questions? Contact Patrick Connole at pconnole@parkplacelive.com.