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CMS launches CRUSH fraud review. What hospital compliance teams should flag

The headlines from CMS’s fraud announcement were about Minnesota and medical equipment suppliers, but the accompanying request for information previews rules on ownership, enrollment and claims timing that could reach every hospital.

3 min read
CMS launches CRUSH fraud review. What hospital compliance teams should flag

Executive takeaway

The CRUSH request for information is an early look at tighter enrollment, ownership and claim timing rules. Quantify exposure to a shorter filing window now and weigh in by March 30 on Medicaid financing questions.

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What CMS announced

At a White House event on Feb. 25, Vice President J.D. Vance, HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Mehmet Oz rolled out three actions:

  • A Minnesota Medicaid deferral of about $259.5 million in federal matching funds, mostly for claims CMS views as unsupported or potentially fraudulent. CMS said it could defer more than $1 billion over the next year if the state does not fix the problems.
  • A six-month nationwide moratorium on new Medicare enrollment, and changes in majority ownership, for certain durable medical equipment, prosthetics, orthotics and supply companies.
  • A request for information on a future rule CMS calls CRUSH, for Comprehensive Regulations to Uncover Suspicious Healthcare, covering Medicare, Medicaid, CHIP and the marketplaces. Comments are due March 30.

CMS also said it plans to publish a list of revoked providers and suppliers with the reason for each revocation. It reported revoking 5,586 enrollments and suspending $5.7 billion in suspected fraudulent Medicare payments in 2025.

Where hospitals come in

The RFI is not a proposed rule, but its questions show where CMS may go. According to a Foley Hoag analysis, items with hospital implications include:

  • Ownership scrutiny. Stronger identity checks for people tied to enrolled entities, possible citizenship or permanent residency requirements for owners with 5% or more interest, and fingerprinting extended to managing employees and smaller owners.
  • Shorter claim deadlines. Cutting the one-year filing window to 90 to 180 days for high-risk services, and possibly for all services.
  • Medicare Advantage billing. Whether every provider billing an MA plan must also enroll in traditional Medicare, and whether MA plans should be directed to suspend payments.
  • Medicaid financing. Questions on supplemental payments, state directed payments and waivers, which many hospitals depend on.

What to do before March 30

A shorter filing window would hit revenue cycle operations hardest, especially for denials, coordination of benefits and late-identified charges. Ask revenue cycle leaders how much of last year’s revenue was billed after 90 and 180 days. Have compliance confirm that ownership and managing employee records in Medicare enrollment are current, since those details may face closer checks. Systems with joint ventures or complex ownership structures should map who would be covered by expanded screening.

Finally, coordinate with your state hospital association. Questions about Medicaid financing tools touch programs that support many hospital budgets, and the record CMS builds now will shape any proposed rule.

Archive entry for Feb 26, 2026, added Nov. 11, 2026.

Sources

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