CRUSH at OMB: The Next Stage of a Twenty-Year Medicare Anti-Fraud Campaign
AI Corner: Chat GPT 5.6; 8-25-2026
The next major Medicare and Medicaid program-integrity proposal is now under review at the Office of Management and Budget. OMB’s public record shows that it received the proposed Comprehensive Regulations to Uncover Suspicious Healthcare, or CRUSH, rule from CMS on August 7, 2026. The OMB listing does not reveal the proposed text or establish a publication date, but it confirms that CRUSH has advanced beyond the preliminary information-gathering stage.
CMS previewed its thinking in a February 2026 request for information on CRUSH (91 FR 9803). That document asked about a strikingly broad range of possible policies. These included faster payment suspensions, stronger enrollment and revocation authority, expanded identity and ownership verification, greater use of prepayment review and data analytics, and new controls for Medicare Advantage, Part D, Medicaid, laboratory testing and durable medical equipment.
The eventual proposal may not include every idea raised in the request. Nevertheless, several possible directions are apparent:
CMS could make it easier to deny, deactivate or revoke the enrollment of providers and suppliers considered high risk.
Payment suspensions and prepayment review could be expanded, including possible requirements for Medicare Advantage and Part D plans to stop payments at CMS’s direction.
Owners, managers and affiliated entities could face additional identity proofing, fingerprinting, background checks and disclosure requirements.
CMS could tighten claim-filing deadlines, surety-bond requirements and restrictions on beneficiary solicitation.
Laboratories—particularly those performing genetic and molecular testing—could potentially receive targeted new oversight,
CRUSH is a major administration priority
CRUSH is not simply a technical project within the CMS Center for Program Integrity. It has become part of a highly visible Trump administration campaign. The initiative received a White House announcement featuring Vice President JD Vance, HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Mehmet Oz. CMS has also told Congress that Dr. Oz and senior agency officials traveled to multiple states to meet with governors, Medicaid directors, tax authorities and law-enforcement officials about coordinated fraud enforcement.
The branding is itself significant. “CRUSH,” the “Fraud War Room” and the administration’s repeated contrast between “pay and chase” and stopping money before it leaves the government are designed for public communication as well as regulatory policy. Press events, state visits, enforcement announcements and prominently advertised dollar figures have made anti-fraud work a recurring part of Dr. Oz’s public leadership of CMS.
The effort also has direct White House sponsorship. President Trump’s Executive Order 14395 establishing the Task Force to Eliminate Fraud (91 FR 13485) placed the task force within the Executive Office of the President, named the Vice President as chairman and included HHS, DOJ, Treasury, OMB and other agencies. The order calls for prepayment controls, identity and eligibility verification, data sharing, provider revalidation, and suspension, termination, exclusion and debarment remedies. It also requires frequent updates to the President.
CRUSH sits within an even broader healthcare enforcement campaign. CMS deferred nearly $260 million in federal Medicaid funding to Minnesota in February while claims were reviewed. In May, CMS announced that it had suspended payments to approximately 800 Los Angeles-area hospice and home-health providers suspected of fraud. It also imposed six-month nationwide enrollment moratoria on hospices (91 FR 27946) and home health agencies (91 FR 27954). These initiatives may not mention CRUSH, but it's in the background.
In July, HHS announced the deferral of an additional approximately $867.5 million for California and $199 million for Minnesota. Those were payment deferrals pending supporting documentation, not permanent funding cuts—an important legal distinction—but the scale and publicity were unmistakable. The White House subsequently assembled these and many non-healthcare actions on a public site describing the administration’s “relentless war on fraud.”
Healthcare fraud is part of a larger governing theme
The administration presents healthcare fraud as one part of a government-wide integrity project. Its public statements and executive actions connect fraud prevention in Medicare and Medicaid with eligibility enforcement in other benefit programs, immigration enforcement and election integrity. Separate actions have directed agencies to strengthen verification of eligibility for benefits received by noncitizens, while election orders have emphasized citizenship verification and protection against claimed voter fraud.
That connection is explicit in the administration’s own documents. The fraud task force order discusses benefit eligibility, immigration integrity and election integrity within a common narrative about identity, eligibility and misuse of public systems. The administration’s election initiatives include the 2025 Executive Order 14248 (90 FR 14005) and the 2026 Executive Order 14399 (91 FR 17125). Its immigration-related actions have likewise emphasized eligibility verification for federally supported benefits.
These policy areas should not be legally conflated. A Medicare payment suspension, an immigration-benefit determination and a state election procedure arise under different statutes, evidence and procedural protections. Politically, however, the administration treats them as expressions of the same governing approach: verify identity and eligibility earlier, share more data, freeze questionable payments before they leave the government and remove parties considered ineligible or high risk.
- This broader context helps explain why CRUSH appears to have unusual momentum. It is supported not only by CMS program-integrity officials but also by the White House’s communications strategy, a vice-presidential task force and an administration-wide emphasis on fraud. Stakeholders should not assume that CRUSH will be a routine proposed rule that attracts attention briefly and then recedes.
CRUSH builds on rules dating to 2006
Although its branding and political support are distinctive, CRUSH does not start from a blank slate. CMS has been strengthening the Medicare enrollment and payment-safeguard system for at least two decades.
2006
The modern framework began with CMS’s 2006 Requirements for Providers and Suppliers to Establish and Maintain Medicare Enrollment final rule (71 FR 20754). That rule required providers and suppliers to submit specified enrollment information, certify its accuracy, report changes and periodically revalidate. It also formalized the principle that receiving an identifier did not by itself create a right to bill Medicare: the provider or supplier had to satisfy enrollment requirements and maintain billing privileges.
The 2006 rule also allowed CMS to verify whether an applicant was operational and to conduct site inspections when necessary. Its preamble described earlier site-visit initiatives involving DME suppliers, independent diagnostic testing facilities, home health agencies and other categories that CMS regarded as vulnerable. Independent laboratories were included within the rule’s program-wide definition of Medicare suppliers, but laboratories were not singled out as the central target.
2008
CMS paired stronger enrollment authority with procedural rules governing adverse actions. Its 2008 billing-privileges appeals rule (73 FR 36448) extended appeal rights for enrollment denials and revocations and established consequences associated with revocation, including reenrollment bars. This structure remains important: stronger exclusion authority must be accompanied by notice, an intelligible factual basis and a meaningful opportunity to challenge an erroneous decision.
2011 - The Big Reform
The largest historical step came after enactment of the Affordable Care Act. CMS’s 2011 Additional Screening Requirements, Application Fees, Temporary Enrollment Moratoria, Payment Suspensions and Compliance Plans final rule (76 FR 5862) divided providers and suppliers into limited, moderate and high-risk screening categories. Depending on category, screening could include license checks, database reviews, site visits, fingerprinting and criminal-background checks.
The 2011 rule also implemented two authorities especially relevant to CRUSH. First, CMS could impose temporary enrollment moratoria in geographic areas or provider categories presenting elevated fraud risk. Second, Medicare and state Medicaid agencies could suspend payments when there was a credible allegation of fraud, subject to specified exceptions. Those concepts—restricting entry and stopping money before completing a full fraud adjudication—are now central to the administration’s strategy.
2014
CMS continued expanding the grounds for exclusion. Its 2014 Medicare provider-enrollment final rule (79 FR 72500) broadened the felony convictions that could support denial or revocation. It also permitted CMS, under specified circumstances, to deny enrollment based on an owner’s relationship with an entity that left an unpaid Medicare debt and to revoke a provider showing a pattern or practice of claims that failed to satisfy Medicare requirements.
2019
The 2019 Program Integrity Enhancements to the Provider Enrollment Process final rule (84 FR 47794) focused on relationships among entities. It authorized disclosure of affiliations with providers or suppliers that had uncollected debt, payment suspensions, exclusions, or enrollment denials or revocations. CMS could deny or revoke enrollment when an affiliation posed an undue risk of fraud, waste or abuse. The rule also strengthened CMS’s ability to address parties attempting to evade prior actions through new names, identifiers or business structures and increased potential reenrollment bars.
Some anticipated CRUSH policies are already appearing elsewhere. The proposed CY 2027 Home Health Prospective Payment System rule (91 FR 41216) contains provider-enrollment provisions that generally would apply across Medicare provider and supplier types. CMS proposed making more revocations retroactive to the date noncompliance began, expanding reenrollment restrictions and allowing revocation when a provider’s location in a saturated geographic area creates a high risk of fraud, waste or abuse. Those proposals offer a preview of the administration’s willingness to use enrollment status as an affirmative enforcement tool.
2006-2019-2026
The historical progression is therefore clear. The 2006 framework established enrollment as a continuing condition of billing. The 2011 rule added risk-based screening, moratoria and credible-allegation payment suspensions. The 2014 and 2019 rules expanded revocation grounds and allowed CMS to examine debts, claims patterns and affiliations. CRUSH 2026 could take the next step by making those tools faster, more integrated and more preventive.
The laboratory industry occupies a distinctive position
Most of this history is program-wide. CRUSH may nevertheless be the first broadly framed CMS program-integrity initiative to make the laboratory industry—especially genetic and molecular testing—such a conspicuous named target.
CMS has a concrete basis for concern. The CRUSH request states that Medicare Part B spent $8.4 billion on clinical diagnostic laboratory tests in 2024. Genetic tests represented only 5 percent of paid test volume but accounted for 43 percent of spending, or approximately $3.6 billion. CMS also reported that its Fraud Defense Operations Center produced $1.8 billion in savings during 2025, including more than $100 million associated with suspect laboratories.
Recent enforcement matters demonstrate the scale of the problem, particularly in Florida and Texas. In 2022, a federal jury in South Florida convicted a laboratory owner in a scheme involving more than $463 million in claims for genetic and other laboratory testing, of which Medicare paid more than $187 million. The evidence involved medically unnecessary testing, kickbacks, telemarketing and orders obtained from physicians who frequently were not treating the beneficiaries.
In 2026, federal prosecutors alleged that two North Texas laboratories billed Medicare approximately $65 million and received approximately $43 million for laboratory services, including genetic testing, allegedly procured through kickbacks. A separate South Florida case alleged a $62 million medically unnecessary genetic-testing scheme involving deceptive telemarketing and the sale of doctors’ orders to laboratories. The Texas and 2026 Florida matters are allegations, not convictions, and the defendants retain the presumption of innocence.
These matters explain why policymakers speak of hundreds of millions of dollars in genetic-testing fraud. They do not, however, justify treating the growth of molecular testing as evidence of fraud. The same period has seen extraordinary and clinically important expansion in cancer genomics.
Genomic biomarker testing is now routinely used to help select treatment for several cancers, including lung, breast and colorectal cancer, according to the National Cancer Institute. Tumor profiling can identify mutations or other biomarkers that make a patient more likely to benefit from a targeted therapy or immunotherapy. Circulating tumor DNA testing may help detect residual disease, identify recurrence earlier and determine which patients are most likely to benefit from chemotherapy after surgery, although important clinical questions remain. NCI has described these ctDNA applications as promising areas of active clinical research.
Molecular testing is also moving toward earlier cancer detection. Multi-cancer early-detection blood tests remain promising with an FDA panel on the topic (reviewing Grail Galleri) soon. The scientific advances behind these tests are potentially transformative for cancer screening and for cancer therapy.
The central policy challenge is therefore discrimination, in both senses of the word: CMS must distinguish brazenly fraudulent schemes from legitimate, medically valuable testing. The most troubling cases commonly involve identifiable characteristics such as deceptive telemarketing, kickbacks, no genuine treating relationship, fabricated or purchased orders, questionable ownership and testing unrelated to a beneficiary’s clinical condition. Those characteristics are very different from properly ordered tumor profiling, hereditary-risk assessment or ctDNA testing integrated into oncology care.
A well-designed CRUSH rule would target the mechanics of fraud without creating indiscriminate barriers to advanced diagnostics. Stronger ownership verification, beneficiary confirmation, scrutiny of marketing arrangements and focused prepayment review could be valuable. But payment suspensions and enrollment actions also require clear standards, prompt review and workable exceptions when delays could interfere with time-sensitive cancer treatment.
The larger significance of CRUSH
CRUSH combines two forces. The first is a twenty-year regulatory evolution toward stronger enrollment screening, broader revocation authority and earlier payment intervention. The second is an unusually public, administration-wide political campaign against fraud, extending from Medicare and Medicaid to other benefit programs, immigration enforcement and election integrity.
That combination makes CRUSH potentially more consequential than an ordinary CMS program-integrity rule. The exact proposal remains unknown while it is at OMB, and its provisions will still have to proceed through notice and comment. But the administration’s repeated announcements, state-level actions, White House task force and personal involvement of Dr. Oz indicate that the initiative has substantial momentum.
For laboratories, the stakes are especially high. Genetic-testing fraud has produced cases involving hundreds of millions of dollars, particularly in Florida and Texas. At the same time, molecular and genomic testing is transforming cancer diagnosis, treatment selection and disease monitoring. The success of CRUSH should therefore be measured not only by how much suspicious billing it stops, but also by how accurately it separates fraudulent business models from legitimate scientific and clinical progress.
