On April 2, 2026, the American Dental Association publicly raised concerns about a proposed federal anti-fraud program that could reshape how dental practices interact with Medicare Advantage plans. The program — CRUSH, or Comprehensive Regulations To Uncover Suspicious Healthcare — was introduced by the Centers for Medicare and Medicaid Services in late February and uses AI and real-time analytics to flag suspicious payments before they leave the system.

For practices that participate in Medicare Advantage through supplemental dental benefits, the proposed rules could mean new enrollment requirements, broader payment-suspension authority for plan sponsors, and AI-driven claim reviews.

What Happened

CMS announced CRUSH on February 25, 2026, and issued a formal Request for Information two days later. The stated goal: shift federal program integrity from a retrospective "pay and chase" model to a proactive "detect and deploy" approach that uses AI to prevent improper payments.

The RFI asks stakeholders to weigh in on several proposals. Three stand out for dentistry:

  1. Dual Medicare enrollment. CMS is considering a requirement that every provider be enrolled in traditional Medicare (Parts A/B) as a condition of billing any Medicare Advantage plan — including supplemental dental benefits.
  2. Expanded payment-suspension authority. CMS is weighing whether Medicare Advantage and Part D plan sponsors should be able to suspend payments during investigations, similar to authority that exists in traditional Medicare.
  3. AI in claims review. CMS is exploring AI for Medicare Advantage risk-adjustment coding and broader claims oversight.

In its March 27 comment letter (covered by ADA News and Becker's Dental), the ADA argued these proposals could create outsized burden for dental practices without meaningfully reducing fraud. Routine dental services are not covered under traditional Medicare, so most dentists have no reason to enroll there; adding a dual-enrollment step would likely discourage dentist participation in Medicare Advantage networks.

On payment suspensions, the ADA noted that dental practices participate in Medicare Advantage only through Part C supplemental benefits. Extending suspension tools designed for costlier medical services to dental claims could have "severe financial consequences" for small and solo practices. The ADA asked CMS to exclude supplemental dental benefits from any expanded suspension authority.

On AI, the ADA acknowledged the promise of the technology but flagged that dental claims data is structured for benefit administration, not for determining medical necessity or detecting fraud. The association urged CMS to require independent validation of AI tools and prohibit insurers from using AI as the sole basis for claim denials or prior authorization decisions.

Why It Matters for Your Practice

Most practices will not feel CRUSH directly tomorrow — the rule is still in the RFI stage. But the proposals have real implications worth tracking:

  • Medicare Advantage participation decisions. If dual enrollment becomes a condition of billing MA plans, practices that accept MA supplemental dental will need to weigh whether to complete traditional Medicare enrollment or drop MA participation — similar to the calculus of renegotiating or dropping insurance networks.
  • Cash flow exposure. A payment suspension during an investigation freezes reimbursements regardless of outcome — a genuine revenue cycle risk for practices where MA supplemental benefits are a meaningful share of collections.
  • AI-driven denials. Insurers are already piloting AI tools to review claims. Practices using AI billing software of their own are better positioned to document medical necessity and respond to AI-driven inquiries.
  • Documentation standards. Practices that have already tightened clinical notes and HIPAA-ready workflows will adapt more easily.

TMR Take: CRUSH is a policy conversation, not a sudden rule change. The dentists who come out ahead will be the ones who submit substantive comments, watch how the final rule lands, and use the next several months to tighten documentation and claim-coding hygiene. This is a moment for engagement, not alarm.

What to Do Now

A few concrete steps while the rule is still being shaped:

  1. Submit comments to CMS. The original CRUSH RFI comment window closed March 30, but CMS is expected to issue follow-on rulemaking. Track the Federal Register (CMS-6098-NC) for related proposed rules and submit dental-specific feedback when they open.
  2. Follow ADA advocacy. The ADA's March 27 letter is publicly posted and worth reading in full. Watch ADA News and your state association for action alerts.
  3. Audit your Medicare Advantage participation. Pull the MA plans you contract with, patient volume tied to each, and share of collections. If dual enrollment becomes required, you will want that data in hand.
  4. Review your traditional Medicare status. Most dentists are opted out, enrolled only to order and prescribe (CMS-855O), or have taken no action. Knowing your current status now makes any future change straightforward.
  5. Tighten documentation. Payer scrutiny is trending toward AI-assisted review regardless of how CRUSH lands. Clean clinical notes and documented medical necessity are the best defense against an AI-flagged claim. For context, see our piece on federal Medicaid changes.

The Bottom Line

CRUSH is an RFI, not a regulation. Nothing about how you bill Medicare Advantage changes today. But the proposals on the table — dual enrollment, broader payment suspensions, AI in claims review — could change the math for every practice that touches MA supplemental dental benefits. The ADA is engaged on behalf of the profession. The most useful thing an individual dentist can do is understand what is being proposed, know their own exposure, and be ready to comment when the next round opens.

Want more coverage of how federal policy shifts hit the chair? Browse our Trending updates for the stories shaping dental practice operations this year.