CMS IS SEEKING INPUT ON AI IN CLINICAL CARE
Article by Michael Tidd, COS-C, HCS-D
CMS has released a 3-page RFI (Request for Information) regarding the use of AI in Clinical Care. They welcome feedback from everyone, but are specifically looking for feedback from clinicians. Do you feel AI is great at helping you with your job? Do you have concerns about how AI can affect your documentation and or patient care?
They’re looking for insights on how existing rules are helping or hindering the development and adoption of AI tools in clinical settings.
Reimbursement. HHS (Health and Human Services) is exploring how reimbursement policies could evolve to better support high‑value AI tools, promote competition among developers, and make effective solutions more accessible and affordable. They’re interested in your ideas on what changes might help accelerate meaningful AI adoption in care delivery.
Research & Development. HHS (Health and Human Services) also wants to strengthen the framework from AI research to real‑world clinical use. They’re seeking input on how federal partnerships could help advance applied AI research, support innovation in care delivery, and open up long-term opportunities across the healthcare ecosystem.
Specific Questions
- What are the biggest barriers to private sector innovation in AI for health care and its adoption and use in clinical care?
- What regulatory, payment policy, or programmatic design changes should HHS prioritize to incentivize the effective use of AI in clinical care and why? What HHS regulations, policies, or programs could be revisited to augment your ability to develop or use AI in clinical care? Please provide specific changes and applicable Code of Federal Regulations citations.
- For non-medical devices, we understand that use of AI in clinical care may raise novel legal and implementation issues that challenge existing governance and accountability structures (e.g., relating to liability, indemnification, privacy, and security). What novel legal and implementation issues exist and what role, if any, should HHS play to help address them?
- For non-medical devices, what are the most promising AI evaluation methods (pre- and post-deployment),
- metrics, robustness testing, and other workflow and human-centered evaluation methods for clinical care? Should HHS further support these processes? If so, which mechanisms would be most impactful (e.g., contracts, grants, cooperative agreements, and/or prize competitions)?
- How can HHS best support private sector activities (e.g., accreditation, certification, industry-driven testing, and credentialing) to promote innovative and effective AI use in clinical care?
- Where have AI tools deployed in clinical care met or exceeded performance and cost expectations and where have they fallen short? What kinds of novel AI tools would have the greatest potential to improve health care outcomes, give new insights on quality, and help reduce costs?
- Which role(s), decision maker(s), or governing bodies within health care organizations have the most influence on the adoption of AI for clinical care? What are the primary administrative hurdles to the adoption of AI in clinical care?
- Where would enhanced interoperability widen market opportunities, fuel research, and accelerate the development of AI for clinical care? Please consider specific data types, data standards, and benchmarking tools.
- What challenges within health care do patients and caregivers wish to see addressed by the adoption and use of AI in clinical care? Equally, what concerns do patients and caregivers have related to the adoption and use of AI in clinical care?
- Are there specific areas of AI research that HHS should prioritize to accelerate the adoption of AI as part of clinical care?
- Are there published findings about the impact of adopted AI tools and their use clinical care?
- How does the literature approach the costs, benefits, and transfers of using AI as part of clinical care?
Access and comment on the RFI (Request for Information) HERE.
Feedback and replies to the RFI (Request for Information) by 5:00PM EST on February 23, 2026.
Questions?
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