AHCA/NCAL submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to a Request for Information (RFI) on the Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative [RIN 0938-AV97]. The CRUSH RFI seeks stakeholder feedback on potential policy approaches to strengthen detection, prevention, and enforcement of fraud-waste, and abuse (FWA) across federal health care programs.
Areas of focus include provider screening, ownership verification, identity proofing, and oversight. The request also reflects broader CMS priorities related to FWA, including DMEPOS supplier oversight, AI-assisted coding risks, and beneficiary protection measures.
Key AHCA/NCAL recommendations from this response include:
- Target fraud-prevention approaches, including AI-based program integrity tools, toward high-risk actors rather than applying broad,…
Investment fraud targets the human desire for financial growth by promising high returns with “low to no risk.”
- Ponzi Schemes: Named after Charles Ponzi, these schemes pay “returns” to earlier investors using the capital brought in by newer investors. There is no actual underlying business; the system collapses when new recruitment slows down.
- Pyramid Schemes: Similar to Ponzi schemes, but participants are usually required to sell a product or service. The primary “profit” comes from the recruitment fees of new members rather than actual product sales.
- Pump and Dump: Fraudsters spread false, positive rumors about a cheap stock (the “pump”) to drive up the price. Once the price peaks, they sell their shares (the “dump”), leaving other investors with worthless stock.