CRUSH RFI Comment vFNL - 3-31-26

Summary: The College of American Pathologists (CAP) supports CMS's efforts to combat healthcare fraud but opposes broad administrative requirements that might penalize compliant laboratories. They specifically urge CMS to reevaluate the MolDX Program and Z-code requirements, arguing they lack transparency and create undue burdens, and instead recommend targeted enforcement and data-driven oversight.