Mehmet Oz, MD, MBA
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: Request for Information Related to Comprehensive Regulations to Uncover Suspicious Healthcare Activity (CRUSH) [CMS-6098-NC]
Dear CMS Administrator:
The Alliance of Specialty Medicine (the “Alliance”), representing more than 100,000 specialty physicians from fifteen specialty and subspecialty societies, is deeply committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we write to provide feedback on the aforementioned request for information (RFI) regarding potential regulatory actions to strengthen
program integrity and uncover suspicious healthcare activity in federal healthcare programs.
General Comments
The Alliance appreciates and supports efforts to identify and prevent fraud, waste, and abuse in Medicare and other federal health programs. We agree that protecting Medicare beneficiaries, safeguarding taxpayer dollars, and preserving the long-term sustainability of the Medicare program are critically important goals, particularly as policymakers face growing concerns about the program’s solvency. At the same time, polices to
address program integrity must be carefully designed to ensure that they do not inadvertently disrupt patient care or impose unnecessary administrative burdens on physicians furnishing medically necessary services to Medicare beneficiaries.
Specialty physicians frequently report that administrative requirements, including utilization management (e.g., prior authorization, step therapy), medical record and documentation requests, and those related to billing, coding and compliance, can delay access to medically necessary care and treatment. When administrative policies are overly rigid or poorly targeted, they risk penalizing physicians acting in good faith while doing little to deter fraudulent actors. As the agency considers new regulatory approaches to strengthen program integrity, we urge CMS to ensure that its policies maintain appropriate safeguards for beneficiary access and specialty physician participation in the Medicare program.
Click here to view the full Response to Request for Information Related to Comprehensive Regulations to Uncover Suspicious Healthcare Activity
