ASE Joins Comments on the Comprehensive Regulations to Uncover Suspicious Healthcare Activity (CRUSH) Request for Information

On March 30, ASE joined the Alliance of Specialty Medicine in submitting comments to CMS in response to the Comprehensive Regulations to Uncover Suspicious Healthcare Activity (CRUSH) Request for Information (CMS-6098-NC). While expressing support for efforts to combat fraud, waste, and abuse in Medicare, the Alliance raised concerns that the newly implemented WISeR Model is increasing administrative burdens on specialty physicians, delaying patient care, and lacking transparency in its use of AI-driven decision tools. The letter urges CMS to pause further WISeR expansion, ensure shortened timely filing deadlines include safeguards for delays outside physicians’ control such as enrollment processing, and maintain clear, objective, and transparent criteria for any changes to the Medicare preclusion list, with meaningful notice-and-comment rulemaking.

Echocardiographers rely on timely access to diagnostic imaging to guide patient care decisions. Expanded prior authorization requirements under the WISeR Model, particularly those driven by automated algorithmic tools, risk delaying essential echocardiography services and imposing additional administrative burdens on practices already navigating complex utilization management processes. ASE’s continues its commitment to ensuring that program integrity efforts do not inadvertently restrict Medicare beneficiaries’ access to high-quality echocardiography and cardiovascular diagnostics.