On February 27 , 2026, the Centers for Medicare and Medicaid Services (CMS) issued a request for information (RFI) on detecting fraud, waste, and abuse in federal health care programsopens in new window. Called the Comprehensive Regulations To Uncover Suspicious Healthcare Initiative, the RFI seeks information from provider groups and other stakeholders to help guide future rulemaking on this topic.
On March 30, APA Services submitted a response to this RFI, which highlights the existing high administrative burdens placed on behavioral health practitioners—including compliance with preauthorization requirements and random audits—that are aimed at curbing “fraud, waste, and abuse” in health care. The response also brought attention to the impact that these burdens have on patient access to care and how they contribute to provider burnout. Furthermore, the response cautions CMS not to conflate increased utilization of behavioral health services with fraud, waste, and abuse, as doing so would lead to inappropriate solutions. Finally, APA Services highlighted potential emerging technologies that could be an appropriate aid in fraud detection with guardrails in place that keep human decision-making capacity at the center of their operation.
While the RFI does not clarify if or when CMS will issue proposed rules on this topic, APA Services staff will continue to monitor the Federal Register for proposed rules on this topic and respond accordingly.
For more information, contact Andrew Strickland.