CMS says licensed clinicians determine nonpayment recommendations
Centers for Medicare & Medicaid ServicesCenters for Medicare & Medicaid Services, model policy page
CMS defends clinician review as a safeguard and says reviewers use standardized, transparent and evidence-based procedures.
“All recommendations for non-payment are determined by appropriately licensed clinicians who will apply standardized, transparent and evidence-based procedures to their review.”
Official statement

Where this statement fits
EFF challenges Medicare's WISeR safeguards; CMS cites clinician review
EFF argues that newly released records show inadequate safeguards in Medicare's WISeR model. CMS says technology and clinician review can prevent inappropriate payments while maintaining coverage rules and patient choice.
Source and context
Official statement
About this source
CMS describes technology-assisted review and clinician decisions. The page was last modified October 19, 2026, and describes the alternative review pathway and excluded services.
Archived copy (opens in a new tab)Before the quotation
CMS describes review of selected services with published coverage criteria and excludes emergency and inpatient-only services.
After the quotation
CMS says coverage rules and provider choice remain unchanged. Providers may choose prior authorization or post-service, pre-payment review.
How this statement is classified
The label describes this statement's response within the context above.
Why this label?
Relative to WISeR's safeguards, CMS offers an affirmative justification for clinical oversight of technology-assisted review.
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- CMS says licensed clinicians determine nonpayment recommendations
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The Dispute Index. "CMS says licensed clinicians determine nonpayment recommendations". First published: 2026-10-28. Last updated: 2026-10-28. https://disputeindex.com/events/7045-cms-defends-clinician-review-as-a-safeguard-and