What the CMS CRUSH Initiative Means for SNF Part B Supply Billing

If you run skilled nursing facilities, you've probably seen the headlines: CMS is cracking down on Medicare fraud harder than it has in a decade, and medical supply companies are at the center of the target. Here's what's actually happening, what it means for the supply-billing arrangement your facility probably has today, and why the operators who move first will be glad they did.

What CRUSH actually is

On February 27, 2026, CMS published a Request for Information in the Federal Register called CRUSH — Comprehensive Regulations to Uncover Suspicious Healthcare. It asked the industry to weigh in on 13 topics that could become formal rules, and the comment window closed March 30, 2026. The proposed rulemaking that follows will shape how Medicare Part B supply billing works for years.

CRUSH didn't arrive alone. In the same stretch, CMS imposed a nationwide six-month freeze on Medicare enrollment for several categories of DMEPOS suppliers — the medical supply companies that bill Medicare for equipment and supplies — citing elevated fraud rates in those supplier types. And the agency published its 2025 enforcement numbers: $5.7 billion in suspended payments, over 122,000 denied claims, and more than 5,500 billing-privilege revocations in a single year.

Read those three things together and the message is unambiguous: CMS believes the supplier-side billing model is where the risk lives, and it is re-engineering Medicare's plumbing around that belief.

Why this lands on your facility's doorstep

Most SNFs today have a "free supplies" arrangement: an outside supplier delivers wound dressings, ostomy supplies, catheters, and trach supplies, bills Medicare Part B under the supplier's NPI, and keeps the reimbursement. Your facility provides the care and the documentation. The supplier collects the check.

That arrangement sits squarely in the population CRUSH is scrutinizing. The RFI's program-integrity topics — tighter supplier enrollment, ownership disclosure, surety bonds, beneficiary-solicitation limits — are all aimed at external suppliers billing Part B under their own NPIs.

Your facility is not the target. But your reimbursement is flowing through the entity class that is.

The detail every operator should circle: the shrinking claims window

Buried in the RFI is a proposal with direct dollar consequences for SNFs: CMS is considering shortening the Medicare Part B claim-filing deadline from 12 months to as little as 90–180 days for high-risk items and services — a category that explicitly includes DMEPOS.

Today, a facility that starts billing Part B supplies under its own NPI can retroactively recover up to 12 months of missed reimbursement. If this proposal becomes a rule, that recovery window could shrink by two-thirds or more. Every month of delay is already a month of unrecoverable revenue; under a 90-day window, "we'll look at this next quarter" becomes "we'll recover almost nothing."

The model that survives CRUSH

Here's the structural irony: the billing pathway CMS is tightening is the supplier-NPI pathway. The pathway it has left untouched — because it's the one the statute and the Claims Processing Manual were built around — is the facility billing under its own institutional NPI, with every claim tied to its own clinical record.

That model answers the exact concerns CRUSH raises:

• Who billed this? The facility that delivered the care, under its own NPI — not a third party.
• Can you prove it was necessary? Yes — the Standard Written Order, the contemporaneous chart, and proof of delivery all live in the facility's own record.
• Does the money trace cleanly? Medicare pays the facility directly. No supplier margin in the middle.

In 2026, Burst submitted a formal public comment to the CRUSH RFI proposing exactly this: facility-side billing as the structural fix to the improper-payment problem CMS is chasing. You can read it on regulations.gov (comment CMS-2026-0826-0507).

What to do this quarter

First, find out what your facilities are leaving on the table — the 12-month retroactive window is still open, and it's worth a real number, not a guess. Second, ask your current supplier one question: "Whose NPI are our residents' Part B supplies billed under?" If the answer is theirs, you now know where your reimbursement is going and which side of the CRUSH lens that arrangement sits on. Third, if you switch to facility-NPI billing, do it with documentation discipline — a claim that can't survive an audit shouldn't be submitted at all.

A free 30-minute assessment will show you exactly what's recoverable from your PointClickCare record, itemized by supply category. No commitment, and if we find nothing, you owe nothing.

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