AAMC Responds to CMS on Fraud, Waste, and Abuse

The AAMC submitted comments on March 26 in response to the Centers for Medicare & Medicaid Services’ (CMS’) request for information related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH). The request focused on how to prevent bad actors from engaging in fraud, waste, and abuse in health care in order to protect taxpayer dollars. The AAMC emphasized its commitment to tackling fraud, waste, and abuse (PDF) and ensuring that Medicare and Medicaid funds are being used within the confines of the law and to benefit Medicare and Medicaid beneficiaries. 

In its comments, the AAMC recommended that CMS maintain the one-year claims filing deadline for most Part A and Part B claims, limiting any tighter deadlines to high-risk actors. Comments also urged the agency to ensure states continue to have flexibility to tailor their Medicaid programs to meet the unique needs of providers and enrollees, including allowing states to use statutorily approved financing mechanisms like intergovernmental transfers and state directed payments. The AAMC further encouraged the CMS to provide oversight of artificial intelligence in prior authorization and in marketing and advertising practices related to beneficiary solicitation practices to ensure beneficiary access to care. Lastly, comments urged the agency not to hold providers accountable for wasteful, abusive, or fraudulent spending that is outside of their control, specifically in Accountable Care Organizations and clinician scores under the Merit-based Incentive Payment System.