APMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to its Request for Information on Fraud Defense Contracts. The comments urge CMS to involve physicians with relevant specialty expertise, including podiatric physicians, in clinical reviews and medical necessity determinations. APMA also called for transparency, validation, and human oversight of artificial intelligence used in fraud investigations.
The comments emphasize distinguishing suspected fraud from inadvertent errors or insufficient documentation and providing meaningful opportunities for physicians to respond to inaccurate findings. APMA recommended evaluating contractors on investigative accuracy, administrative burden, and patient access alongside financial outcomes to help ensure fraud prevention efforts do not disrupt medically necessary care.