CMS took comments on new physician policies and new hospital outpatient policies until mid-September. The final rules will come out circa November 1, although that may vary due to the government shutdown.
In the meantime, you can search the thousands of comments by keyword (including author).
My August blog on "how to comment" is here.
Search the 13,000 PFS comments here.
Search the 4,000 OPPS comments here.
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For example, CMS sought comments in both the OPPS and PFS rules on how it should value and price digital services. One notable commenter would be the Heartflow company.
PFS - Heartflow
Searching the 13,000 PFS comments for Heartflow gives one document - the 7-page Heartflow comment dated September 9, 2025. While they comment on software-mediated valuation in some detail, it's framed as how to price a new Heartflow code (and not so much as an answer to CMS's more general RFI on valuation).
PFS - AI
I searched the 13,000 PFS comments for "artificial intelligence," and to my surprise, there were only 3 hits. One was from "Radiology Partners," one from a PhD physical therapist (5pp), one from a cardiology device clinic in Utah. However, I think this is incomplete, for example, the AMA PFS comment (116pp) mentions "artificial intelligence" at least twice. AMA writes,
Newer technologies, including artificial intelligence (AI) software, frequently generate substantially more images and sequences than were previously available. A Computed Tomography (CT) study that once consisted of 40 images now frequently contains 400 or more. In addition, AI tools often highlight or flag findings that then require further physician review, confirmation, or correlation with other studies. This process adds uncompensated time and cognitive effort to the physician’s workload. Far from creating net efficiencies, these innovations can increase the interpretive and documentation burden.
PFS - SaaS
This yielded 9 hits, so clearly there is something quirky about searching for "artificial intelligence" alone. PathAI submitted a 10-page comment to the RFI. They propose that CMS create 4 standardized codes for assistive and other classes of AI (p. 8).
OPPS - Heartflow (& AI)
Turning to the OPPS comment, we again search "Heartflow" and find 1 comment, this one 17 pages. Here at OPPS, "artificial intelligence" with or without quotes yield 0 hits. Pulling down the AHA's 70 page comment, artificial intelligence is mentioned several times, including a response to the RFI, page 68. So the searching is quirky.
OPPS - SaaS
Searching the OPPS comments for "SaaS" generated 9 hits. (One was "me.") Artera submitted a 7-page comment which discusses 7 key principles for SaaS valuation. Premier submitted a 20-age comment, commenting on the RFI for SaaS on page 5-6/ (See also Premier's comments on diagnostic radiopharmaceuticals on page 6.)
