Industry Watch Alert
On February 26, 2026, the CMS, HHS and the White House collectively announced CRUSH, a coordinated expansion of their fraud, waste, and abuse strategy with direct implications for payer operations, utilization management, and program integrity governance.
The collaborative expanded fraud prevention actions directly affect payer organizations by raising expectations around utilization management rigor, vendor oversight, and defensible decision-making in high-risk service areas. As CMS shifts toward real-time enforcement and greater transparency, payers should anticipate increased scrutiny of claims integrity, network controls, and documentation standards that support compliant, consistent coverage decisions.
Key Takeaways
(click each section below to expand)
Stakeholder input is being solicited through the CRUSH initiative, signaling potential future regulatory changes across Medicare, Medicaid, CHIP, and the Health Insurance Marketplace.
The Trump Administration is elevating fraud prevention as a core affordability strategy, shifting enforcement upstream to stop improper payments before they occur.
CMS, under Administration and HHS direction, is executing expanded program integrity actions, including Medicaid funding deferrals, supplier enrollment restrictions, and increased transparency.
Payer organizations should expect sustained scrutiny, with higher expectations for utilization management rigor, documentation, and defensible decision-making.
The Impact
The Trump Administration announced a coordinated set of fraud prevention actions across Medicare and Medicaid, signaling a sustained federal shift toward affordability, program integrity, and real-time enforcement. Announced by leadership from the White House, HHS, and the Centers for Medicare & Medicaid Services, the initiative reflects a move away from post-payment recovery toward preventing improper payments before funds are released.
As the primary enforcement agency, CMS is executing several high-impact actions:
Medicaid Funding Deferral: CMS deferred $259.5 million in federal Medicaid matching funds to Minnesota following findings of unsupported or potentially fraudulent claims, primarily tied to personal care services, home and community-based services, and other practitioner services. CMS indicated additional deferrals could follow if corrective actions fail to address underlying program integrity gaps.
DMEPOS Enrollment Moratorium: CMS implemented a six-month nationwide moratorium on new Medicare enrollment and ownership changes for certain DMEPOS suppliers, targeting longstanding fraud risks within this category.
Expanded Transparency: CMS will publish information on revoked Medicare providers and suppliers, including NPIs and revocation rationale, increasing visibility for payers and other stakeholders.
Collectively, these actions underscore a federal shift toward data-driven prevention, proactive oversight, and front-end controls. For payer organizations, this raises expectations around utilization management consistency, documentation rigor, and supplier and vendor oversight in high-risk service areas.
What to Watch Next
- CRUSH Initiative Rulemaking: The Administration is seeking stakeholder input on strengthening fraud prevention authorities and regulatory approaches, signaling the potential for future rulemaking with operational implications for payers.
- Expanded Use of Advanced Analytics: Federal leadership has explicitly framed fraud prevention as a real-time function supported by advanced analytics and AI-enabled oversight.
- State Medicaid Oversight: The Minnesota deferral signals a willingness to apply aggressive fiscal controls when program integrity safeguards are deemed insufficient.
- Supplier and Network Risk Management: Public disclosure of revocations may become a new data input for payer credentialing, network oversight, and utilization management workflows.
Stakeholder comments on the CRUSH Request for Information are due March 20, 2026, reinforcing the near-term momentum behind this initiative.
As federal leadership elevates fraud prevention as a core affordability strategy, payer organizations may want to take a closer look at how program integrity, clinical review, and governance structures support consistent, well-documented decision-making across Medicare and Medicaid. We can help.
Previous Alerts
Sources
Centers for Medicare & Medicaid Services.
Trump Administration Prioritizes Affordability by Announcing Major Crackdown on Health Care Fraud.
CMS Press Release, 2026.
Federal Register.
Medicare, Medicaid, and Children’s Health Insurance Programs; Nationwide Temporary Moratoria on Enrollment of Certain DMEPOS Suppliers.
Federal Register, 2026.
Federal Register.
Request for Information: Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH).
CMS-6098-NC, 2026.
Centers for Medicare & Medicaid Services.
Fraud Prevention and Program Integrity Overview.
Fraud
FAQs
What is the CMS CRUSH initiative?
The CRUSH initiative is a federal effort to strengthen fraud prevention across Medicare, Medicaid, CHIP, and the Health Insurance Marketplace by expanding real-time detection, enforcement authority, and program integrity oversight, with implementation led by the Centers for Medicare & Medicaid Services.
How will the CRUSH initiative affect Medicare and Medicaid?
CRUSH is expected to increase front-end fraud prevention, expand data-driven oversight, and raise expectations for documentation, utilization management consistency, and defensible payment decisions across Medicare and Medicaid programs.
Will the CRUSH initiative lead to new regulations for payers?
CMS has indicated that stakeholder input submitted through the CRUSH Request for Information may inform future rulemaking, which could introduce new or expanded regulatory requirements affecting payer program integrity and oversight practices.
When are comments due for the CMS CRUSH Request for Information?
Comments on the CMS CRUSH Request for Information must be submitted by March 20, 2026, through the Federal Register.
Each week, we email a summary along with links to our newest articles and resources. From time to time, we also send urgent news updates with important, time-sensitive details.
Please fill out the form to subscribe.
Note: We do not share our email subscriber information and you can unsubscribe at any time.
Partner with BHM Healthcare Solutions
BHM Healthcare Solutions offers expert consulting services to guide your organization through price transparency & other regulatory complexities for optimal operational efficiency. We leverage over 20 years of experience helping payers navigate evolving prior authorization requirements with efficiency, accuracy, and transparency.
Our proven processes reduce administrative errors, accelerate turnaround times, and strengthen provider relationships, while advanced reporting and analytics support compliance readiness and audit preparation. From operational improvements to strategic positioning, we partner with organizations to turn regulatory change into an opportunity for clinical and business excellence.