The Council for Affordable Health Coverage submitted comments in response to the Centers for Medicare & Medicaid Services’ Request for Information (RFI) regarding potential regulatory and programmatic changes that could strengthen federal health program integrity under the agency’s Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative.
In its comments, CAHC stated that CMS is correct to pursue a more modern fraud prevention framework. As fraud schemes evolve – particularly those involving identity theft, automated application attacks, and sophisticated billing patterns – program integrity must shift from a reactive “pay-and-chase” model to a prevention-oriented system that stops improper payments before they occur. CAHC believes CMS can achieve this goal through a strategy built on five pillars:
- Preventing fraud at the front door of federal health programs
- Strengthening Provider Enrollment Oversight and Use of Existing Authorities
- Strengthening Managed Care Integrity and Outcomes-Based Oversight
- Improving Data Analytics and Payment Accuracy
- Addressing Structural Sources of Waste and Improving Payment Design