CRUSH, O&P, and a Better Way to Fight Fraud

If you own, manage or work in an O&P practice, you are already feeling the pressure of a more fraud-sensitive reimbursement environment. CMS’s CRUSH initiative—Comprehensive Regulations to Uncover Suspicious Healthcare—signals a broader push to tighten oversight, especially in DMEPOS, where CMS has already taken concrete anti-fraud actions and publicly described the category as high risk for fraud, waste, and abuse. For legitimate O&P clinics, the question is not whether CMS should fight fraud. The question is whether CMS can do it in a way that targets bad actors without making compliant practices carry even more administrative burden. 

One practical idea deserves more attention: require the individual orthotist, prosthetist, or fitter who rendered the care to be identified on every claim with an NPI. The concept is simple. Medicare would continue paying the enrolled facility, but the claim would also identify the treating clinician, giving CMS better visibility into who is really evaluating, fitting, and delivering care. That kind of individual-level data would make it easier to spot implausible billing patterns, cross-facility credential misuse, and other behavior that broad facility-level billing can hide today.  

What CRUSH Means for O&P

CRUSH is still in the policy-development stage, but its direction is clear. In February 2026, CMS published a formal Request for Information seeking ideas for regulatory changes to better detect and prevent fraud, waste, and abuse across Medicare, Medicaid, CHIP, and Marketplace plans. Legal and policy summaries of the RFI note a particular focus on DMEPOS suppliers, including stronger enrollment controls, new screening tools, expanded data use, and more sophisticated prepayment oversight. 

That focus matters in O&P because honest clinics and bad actors are still grouped under the same broad DMEPOS umbrella. CMS has paired the CRUSH RFI with other visible anti-fraud steps, including a six-month nationwide moratorium on new Medicare enrollment and certain ownership changes for some DMEPOS supplier categories. Whether or not an individual O&P clinic has done anything wrong, it is operating in a category CMS clearly views as a program-integrity concern. 

Why the NPI Idea Matters

The proposal is appealing because it is targeted, practical, and built on infrastructure Medicare already uses elsewhere. It recommends that certified orthotists, prosthetists, and fitters obtain and use an individual NPI, enroll through a new “individual supplier” pathway (mimicking the provider pathway), and be identified in existing claim fields as the rendering clinician while leaving billing, supplier, and payment rules unchanged. The point is not to create another layer of bureaucracy for good practices. The point is to give CMS a clearer line of sight into who actually treated the patient.  

That change could help in several ways. It would allow CMS to confirm that the person fitting the device is “qualified” and enrolled, track volume and geography at the individual clinician level, and identify suspicious patterns such as one person appearing to treat implausible numbers of beneficiaries or showing up across multiple distant locations on the same day. It would also make “credential rental” schemes easier to detect by connecting individual clinicians to specific service patterns instead of relying only on facility billing records. Most important for legitimate providers, it offers a smarter way to distinguish real clinical practices from anonymous supply operations or sham arrangements hiding behind a company name. Further, this process takes us one step closer to splitting custom O and P from DME.  

Why You Should Speak Up Now

The formal CRUSH comment window is closed, but that does not mean the conversation is over. CMS continues to work through contractors, provider outreach channels, and stakeholder engagement pathways, and Medicare Administrative Contractors remain an important touchpoint between you and the Medicare system. If you want this idea to stay alive, the most practical next move is not a generic note to Congress. It is targeted feedback to the DME MACs that educate suppliers, hear recurring pain points, and relay operational concerns upstream. 

This is also a smart advocacy lane for busy O&P clinics because it is concrete. Instead of complaining that audits are unfair or prior authorization is burdensome, readers can offer a constructive solution: identify the treating clinician on every claim so CMS can better target fraud while reducing the need for blunt, category-wide crackdowns. That is the kind of recommendation a MAC can understand, discuss, and elevate because it connects directly to claims processing, supplier enrollment, and program integrity.  You can see a public comment that addresses this concern here.

A Better Call to Action

If this idea makes sense, take five minutes and communicate it to your DME MAC. Mention it during a MAC education event, reply through a provider contact channel, or send a short note explaining that O&P clinicians should be individually identifiable on claims just as other rendering providers often are. The goal is not to ask the MAC to write national policy on its own. The goal is to make sure the people closest to DMEPOS operations keep hearing the same message from legitimate providers: give CMS better data on who actually rendered care, and it will be easier to target fraud without punishing compliant clinics.

Fraud prevention matters. Patient access matters too. O&P practices should not sit quietly while others decide how to balance the two. A system that can see the individual clinician behind the claim is more likely to catch the people gaming Medicare and less likely to burden the clinics doing the work the right way. 

Here is a short paragraph you can copy, personalize, and send: 

I am a credentialed O&P professional/practice leader serving Medicare beneficiaries. As CMS looks for better ways to fight fraud in DMEPOS, I encourage the DME MACs to support a policy that identifies the individual clinician who actually provides orthotic or prosthetic care on each claim using an NPI, while leaving facility billing and payment rules in place. This would give Medicare better visibility into who treated the patient, help detect implausible billing or credential-rental schemes, and better distinguish legitimate O&P clinics from bad actors, all with relatively little operational burden because the NPI and claim-field infrastructure already exists.