The American Orthotic and Prosthetic Association (AOPA) submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) in response to its Request for Information on the proposed Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) Initiative. The initiative is focused on strengthening program integrity and reducing fraud, waste, and abuse in Medicare.
In its comments, AOPA said it supports efforts to eliminate fraud, but those efforts must also protect access to high-quality, clinically appropriate O&P care and avoid unnecessary burdens on qualified providers.
AOPA highlighted several priorities:
- Preventing bad actors before they enter the system by strengthening enrollment screening and oversight
- Expanding prior authorization thoughtfully to reduce fraud while ensuring timely access to care
- Moving away from “pay and chase” models by investing in smarter, more proactive systems
- Improving oversight of Medicare Advantage plans to prevent fraud from shifting across programs
- Strengthening protections for beneficiaries by addressing misleading marketing and inappropriate solicitation
- Ensuring qualified providers deliver custom care, reinforcing existing standards under federal law
- Advancing the Medicare O&P Patient-Centered Care Act, which directly supports fraud prevention while improving patient access
To read the full comments, visit AOPA’s website.
