In the past few days, I've highlighted the ACLA comment on "CRUSH" (the CMS fraud initative), the ACLA letter being on the ACLA website. I've also noted that BCBS commented on CRUSH and MolDx, having seen the BCBS 54 p letter posted in a Linked In article.
You can't find these (or my letter) from the CMS website, at least not yet.
If you go to the CRUSH website, https://www.regulations.gov/docket/CMS-2026-0826
...it says 768 comments submitted, and 341 posted. (Comments were due a week ago).
Among the 341 posted, I searched for "MolDx" (capitalization did not matter) and it gave me 17.
But not found are the ACLA letter, the BCBSA letter, nor, for example, my own letter.
What you get is almost entirely individuals who are complaining to CMS that MolDx has not covered a ductal carcinoma related test. (NOT a comment on the CMS fraud initiative.)
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Hopefully CMS just has a backlog of post-able comments (768 submitted - 341 so far online = 427 remaining) and will eventually post them all.
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Here is a four-page anti-MolDx letter. It emphasizes the need for, and increasing difficulty of, 87798 payments, recently targeted for anti-fraud actions at some MACs.
https://downloads.regulations.gov/CMS-2026-0826-0225/attachment_1.pdf
