Nursing home providers are urging the Centers for Medicare and Medicaid Services (CMS) to proceed carefully with its anti-fraud initiative for health care, warning that overly broad enforcement actions could increase administrative burden and disrupt patient care.
The federal agency, which introduced its Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative in late February, asked the health care industry for feedback on proposals including stricter provider screening, AI-based oversight and shorter claims filing deadlines.
The skilled nursing sector, already widely seen as over-regulated by nursing home providers, could face even more scrutiny, compliance pressure and operational burdens if CMS expands the fraud enforcement without targeted safeguards for providers, sector advocacy groups noted in their comments to CMS.
According to Jodi Eyigor, vice president of health policy at LeadingAge, the largest association of nonprofit providers, including nursing homes, the CRUSH initiative will be redundant with oversight efforts already underway for nursing homes.
“[It] brings to mind longstanding CMS oversight in nursing homes with measures like ownership transparency that are already in place,” Eyigor said in an emailed statement to Skilled Nursing News. “Looking ahead, if CMS applies lessons from its more aggressive fraud efforts in hospice and home health, then nursing homes could face increased oversight and compliance expectations, underscoring the need for targeted, well-calibrated enforcement.”
Meanwhile, the largest advocacy group for long-term care providers representing 15,100 members, the American Health Care Association and National Center for Assisted Living (AHCA/NCAL), cautioned CMS against applying blanket fraud-prevention measures that could penalize legitimate providers, including nursing homes.
“Providers submitting enrollment data regarding ownership will be submitting sufficient information that could easily be verified through those channels, rather than adding on more costly and time-consuming reporting, fingerprint and criminal background requirements for additional lower risk parties on top of the existing requirements of owners,” AHCA/NCAL stated in comments submitted as part of CMS’ request for information (RFI).
Moreover, such broad oversight would needlessly burden a vast majority of providers, who are already playing by the rules, AHCA’s comment noted.
“Most providers are legitimately submitting appropriate claims and should not be subject to additional arbitrary burdensome pre- or post-pay audits processes when AI technology could more effectively prevent and identify potential fraud activity under existing statutes and regulations by targeting high-risk activity,” AHCA’s comment read.
However, the nursing home advocacy group also raised concerns about CMS’ potential use of artificial intelligence in fraud oversight. While AI tools could help verify provider enrollment data and target high-risk activity more efficiently, human oversight would still be necessary to prevent inappropriate audits or denials for providers serving specialized or high-needs populations, AHCA/NCAL said.
“AI driven recommendations for audits or denials, whether pre- or post-pay, should have human oversight to assure that specialty providers or those with unique patient populations are not disproportionately targeted for audits or claim denials which can directly impact beneficiary access to care if they have conditions or care needs that require specialized services,” the group’s comment noted
The CRUSH program follows President Donald Trump’s directive issued in June 2025 to eliminate waste, fraud and abuse in Medicaid.
“CMS is done trying to catch fraudsters with their hands in the cookie jar – instead, we’re padlocking the jar and letting them starve,” CMS Administrator Dr. Mehmet Oz said back in February when CRUSH was introduced. “This proactive approach will help us crush fraud, protect taxpayer dollars, and make sure the vulnerable Americans who depend on our programs get the care they need.”
CMS’ RFI sought input from a broad range of health care providers on new and existing strategies to strengthen fraud prevention, detection and oversight across Medicare, Medicaid and other health care programs. The agency also encouraged comments from states, providers, suppliers, payers, technology companies, patient advocates, beneficiaries and others.
The RFI was released on February 27, and the comment period ended on March 30.
