March 30, 2026
The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Submitted Electronically
RE: CMS–6098–NC Request for Information (RFI) Related to Comprehensive Regulations To Uncover Suspicious Healthcare (CRUSH)
Dear Administrator Oz:
On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS’) Request for Information (RFI) Related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH).
The AHA supports CMS’ efforts to combat…
HOW TO SPOT A “RED FLAG” (THE BEHAVIORAL AUDIT)
Keep an eye out for these behavioral shifts in your staff:
Refusal to take leave: Afraid someone will find their “adjustments.”
Unexplained wealth: Buying luxury items that don’t match their known salary.
Working odd hours: Preferring to work alone late at night when no one is watching the system.
“Gatekeeper” behavior: Becoming overly defensive or angry when someone asks to see their records.