Research · Regulatory commentary

RFI submissions & policy responses.

Public comment letters, RFI responses, and policy positioning. Practitioner-informed, regulations.gov-published, and grounded in production deployment evidence.

Published submissions

On the public record.

  • The 2026 AI Prior Authorization Vendor Landscape — Payer-Side

    Seven payer-side AI PA vendors (Anterior, Cohere Health, Genzeon HIP One, Humata Health, Innovaccer, Microsoft Foundry PA Accelerator, Optum + Change Healthcare) evaluated against seven 2026-specific criteria including CMS WISeR participation, citation architecture, and auto-denial posture. Written from inside a CMS WISeR production deployment with full methodology disclosure.

  • The 2026 AI Prior Authorization Vendor Landscape — Payer-Side

    An inside view from CMS WISeR. Seven payer-side AI PA vendors evaluated against seven 2026-specific criteria — production deployment, regulatory program participation, per-criterion citation architecture, coverage breadth, auto-denial posture, patent depth, independent validation. Published with full disclosure: Genzeon is one of the seven vendors evaluated.

  • 21st Century Cures Act — Information Blocking Walkthrough

    Practitioner-grade walkthrough of the Cures Act information blocking rule (45 CFR Part 171). What the rule says, how OIG enforces it, the eight exceptions, the September 2023 enforcement go-live, and how CPS One operationalizes Cures Act compliance inside the privacy program.

  • March 30, 2026 · CMS CRUSH RFI Submission

    Five-part response on regulations.gov to the CMS Crush Bureaucracy and Reduce Unnecessary Administrative Burden RFI. Practitioner-informed positioning across PA automation, FHIR adoption, and provider burden reduction. Anchored by live WISeR deployment evidence.

  • WISeR Provider Guide v5.0 — Practitioner Walkthrough

    Provider-side decoding of the CMS WISeR Provider/Supplier Operational Guide v5.0 (March 12, 2026). Seven things NJ providers should know about WISeR, from the team running it.

  • CMS-0057-F Position Notes

    Cross-reference: see the CMS-0057-F Field Guide for the practitioner-grade rule walkthrough.

For policy positioning written for engineering audiences, see field notes. For live deployment evidence, see /wiser.