What America’s Health Data Thinks: Visualizing CMS RFI Comments

By Eugene Vestel | July 2025

CMS recently issued a Request for Information (RFI) on the future of digital health policy, patient access, and interoperability. The comments are now in — and I’ve built a tool to help make sense of the wide-ranging responses.

But first, a big disclaimer 👇

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⚠️ Disclaimer: About the Data

All insights and visualizations in this post are based on publicly submitted comments in response to CMS’s RFI:

📝 CMS RFI: Request for Information – Health Technology Ecosystem (CMS-2025-0050-0031)

📥 Public comments were aggregated via an open-source browser created by Josh Mandel:
🔗 CMS RFI Aggregator by Josh Mandel

🧰 My visualizer tool simply builds on Josh’s data aggregation to enable interactive filtering, stakeholder views, and thematic clustering:
🔍 Explore the CMS RFI Response Visualizer

These tools reflect publicly available data. They do not represent an official analysis or endorsement by CMS, ONC, or any affiliated agency. This work is entirely independent and for community education and insight.

🧩 Stakeholder Landscape: Who Responded?

The visualizer lets you filter and explore by stakeholder type. Here’s what emerged:

• Payers: Emphasizing data liquidity, TEFCA participation, and payer-to-payer use cases.

• Providers: Focused on burden, patient access, and identity challenges.

• Vendors: Calling for clarity around FHIR versions, certification, and testing frameworks.

• Advocacy Orgs: Prioritizing equity, patient rights, and public accountability.

• Open Source/Indie Contributors: Rich in technical nuance and implementation advice.

📌 Observation: While vendors submitted the most responses, the most technically detailed and forward-looking submissions came from open-source and research communities.

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