Families USA Submits Comments on Request for Information (RFI) Related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH)

Families USA appreciates the opportunity to provide input to the Centers for Medicare & Medicaid Services (CMS) in response to the request for information (RFI) regarding potential regulatory or programmatic changes that the agency could pursue to bring better oversight and accountability to Medicare and Medicaid.

In the first part of our comments, we recommend that this administration’s efforts to address waste, fraud and abuse be targeted to meaningfully ensure accountability in the health care system, without resorting to drastic and destabilizing measures (e.g. after-the-fact Medicaid funding deferrals as recently done in Minnesota) or utilizing counterproductive efforts that misplace their focus on beneficiary use of services or misuse metrics like payment error rates which are not indicative of fraud.

We welcome the opportunity to continue our work with CMS on a broad range of issues related to accountability and oversight over the plans and providers in Medicaid, Medicare, and the Marketplaces in order to better prevent improper or fraudulent payments before they occur. In this vein, the second part of our comments provide responses to the RFI focused on the need for greater oversight over Medicaid Managed Care Organizations (MCOs) — many of which are massive for-profit health care corporations. We recommend five areas for greater transparency by Medicaid MCOs: prior authorization practices, medical loss ratio reporting, sanctions, contracts, and procurement best practices. These efforts would help facilitate a more efficient and effective Medicaid program and better highlight specific vulnerabilities to waste, fraud, and abuse in our health care system.