ICATRFI007062026.docx

REQUEST FOR INFORMATION (RFI) - Intelligent Coding Assistance Tool Agency/Office:

Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) Centers for Consumer Information and Insurance Oversight (CCIIO) Payment Policy & Financial Management Group (PPFMG)

Project Title: HHS-Operated Risk Adjustment Data Validation Program (HHS-RADV) Intelligent Coding Assistance Tool (ICAT) RFI #2 Response Date: August 20, 2026

1. BACKGROUND: The purpose of HHS-RADV is to promote confidence in the risk adjustment program set forth in Section 1343 of the Patient Protection and Affordable Care Act (ACA) by validating the integrity and quality of data provided by issuers via External Data Gathering Environment (EDGE) servers for the purpose of operating the risk adjustment program in state market risk pools where HHS operates the risk adjustment program. The HHS-RADV audit for a benefit year begins almost immediately following the data submission deadline for that benefit year. For example, the risk adjustment data submission deadline for the 2024 benefit year was April 30, 2025. HHS-RADV samples for the 2024 benefit year audit were generated in May 2025. The 2024 benefit year HHS-RADV results will be reported in June 2026 and HHS-RADV adjustments to the 2024 benefit year risk adjustment transfers will be reported in July 2026.

1. SUMMARY: The Centers for Medicare & Medicaid Services (CMS) is issuing a second Request for Information (RFI) as a means of conducting market research to determine the availability and potential technical ability to procure an AI tool that is compatible with or integrated within Salesforce that consolidates from various sources discrete medical chart/record values for diagnosis abstraction.

CMS issued an RFI on November 17, 2025 , and this is a follow-up to that original RFI. Please see the previous RFI for background information including technical flows and regulatory citations and a full discussion.

To support clear and concise submissions, we divided this RFI into three; technical feasibility, operations and maintenance, and acquisition strategy.

CMS is issuing this Request for Information (RFI) as a means of conducting market research to determine the availability and potential technical ability to procure a tool that is compatible with or integrated within Salesforce that consolidates from various sources discrete medical chart/record values for diagnosis abstraction. We are seeking a tool that can be deployed initially within 6 months of award and then maintained and enhanced going forward. We are considering a FY 27 procurement meaning CMS is seeking to procure a developed product that requires limited customization and integration with Salesforce.

This tool should be able to populate the initial review template after accounting for HHS-operated risk adjustment and medical chart/record review requirements. Specifically, this tool will facilitate SVA primary coders and HCC validation. CMS intends to use this tool to facilitate enhanced and more accurate first-level medical chart/record review and diagnosis abstraction for the HHS-RADV program, specifically as part of the second validation audit (SVA) (see 45 CFR 153.630). CMS is evaluating the appropriate ICAT from a wide range of commercial off-the-shelf (COTS) products, open-source solutions, and artificial intelligence (AI) options from various vendors and research institutions. Our primary goals are:

a. Reduce the time for medical coders to reach accurate conclusions for SVA decisions.

b. Facilitate the review of medical charts/records more quickly than and as accurately as a human medical coder, notating and synthesizing relevant diagnostic information within the medical chart/record, and identifying relevant sections of medical chart/record and diagnosis codes with the same accuracy as or better than a human medical coder;

c. Reduce burden and CMS costs associated with hiring medical coders to complete HHS-RADV, specifically the SVA portion of HHS-RADV;

d. Improve efficiency and performance through progressive use and correction; and

e. Demonstrable and achievable financial and functional return on investment (ROI) within a reasonable timeframe.

Under 45 CFR § 153.630, a senior reviewer must confirm any enrollee risk adjustment error discovered during the initial validation audit (IVA). For purposes of this section, a “senior reviewer” is a human reviewer certified as a medical coder accredited by a nationally recognized accrediting agency who possesses at least 5 years of experience in medical coding. CMS therefore will likely restrict this tool to first-level review, but we welcome discussion (pros and cons) regarding potential use cases during “senior review” in later sections of this RFI.

2. Technical Feasibility: This RFI is seeking solutions to be deployed in—or interact seamlessly with—our Salesforce, for instance, called the CCIIO Customer Service Response Management System (CCRMS). We are seeking solutions that can be deployed within 6 months (at least in pilot form) and do not require significant custom coding. Our preference is to leverage AI tools native capabilities to the greatest extent practicable, avoiding significant custom coding that could increase implementation risk. In addition, we are seeking information regarding:

· The potential offeror’s proposed architectural solution

· Implementation roadmap and timetable

· Security and related FEDRAMP certifications

· Interfaces with Salesforce

· Historical interactions with CMS systems

3. Operations and Maintenance: This RFI is also seeking information on the ongoing costs (licensure, tokens, etc.), updates, and other requirements for ongoing maintenance. CMS wants to ensure that we achieve a return on investment (savings in labor) and can deploy additional funding for continuous improvement to this solution over the lifecycle, providing doing so will result in continual measurable ROI. In addition, we are seeking information regarding:

· The potential offeror’s plan for operations and maintenance

· Annual updates or continuous improvements

· Workflows

· Return on investment metrics

· Dependencies

4. Acquisition Strategy: Finally, this RFI is seeking information on contract strategy, requirements definition (Performance Work Statement or Statement of Objectives) and preferred teaming arrangements for optimal delivery. CMS wishes to ensure that there are no sourcing constraints between the RADV professional services acquisition vehicle and the ICAT acquisition vehicle. We request information on best methods to procure discrete aspects (or modular parts) of the proposed ICAT solution.

5. Conflict of Interest: In RFI #1, CMS stated that any ICAT solution must follow the requirements are satisfied and discussed the regulatory citation 45 CFR § 153.630(b)(3):

6. RESPONDING TO THIS REQUEST:

THIS IS A REQUEST FOR INFORMATION ONLY. This RFI is issued solely for CMS’ information and planning purposes. This RFI does not constitute a Request for Proposal (RFP) or a promise to issue an RFP in the future. This RFI does not commit the Government to contract for any supply or service. At this time, CMS is not soliciting quotes/proposals. Respondents are advised that the U.S. Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the respondent’s expense. Not responding to this RFI does not preclude participation in any future procurement. It is the responsibility of the interested vendors to monitor this site for additional information pertaining to this requirement. Information provided in the RFI is subject to change and is not binding on the Government. HHS, CMS, or OAGM have not made a commitment to procure any of the items discussed, and release of this RFI is not a commitment or an authorization to incur cost for which reimbursement would be allowed or sought.

Proprietary information and trade secrets, if any, must be clearly marked on all materials. All information received in response to this RFI that is marked “Proprietary” will be handled accordingly. Please be advised that all submissions become Government property and will not be returned, nor will the receipt be confirmed. Respondents will not receive feedback on their submission. No basis for claims against the United States Government shall arise as a result of a response to this RFI or from the United States Government’s use of such information.

Responses to this RFI shall be submitted no later than 10:00 AM local prevailing time on August 20, 2026 to Andrew Mummert, Contracting Officer, at andrew.mummert@cms.hhs.gov, in a format that is readable in Microsoft Word or Adobe PDF document with page size 8.5 by 11 inches, with a minimum of 1” margins. Calibri Font Size 11 with no less than single spacing between lines is required. Please note that a response to every question is not required. Responses will be no more than 3,000 characters per question. CMS will accept up to 10 additional Appendix pages to accommodate blueprints or other technical documentation. CMS will not accept hard-copy responses or other formats. All responses to the RFI shall contain ‘HHS-RADV- ICAT RFI – Company Name’ in the response email's subject-line.

Section I. – General Vendor Information: General Vendor Information to include the following:

· Organization Name

· Mailing address

· Name, phone number, and e-mail address of designated point of contact

· Business type (large business, small business, small disadvantaged business, 8(a)-certified small disadvantaged business, HUBZone small business, woman-owned small business, very small business, veteran-owned small business, service-disabled veteran-owned small business).

· Any current or previous federal contracts in the GSA, Governmentwide Acquisition Contracts (GWAC), or any other relevant federal contracts held by your organization.

Section II. The name and contact information of the organization whose views are represented in the submission, if different from the information provided in Section I.

Section III. Respondents are encouraged to provide complete but concise responses to the questions listed below. Please note that a response to every question is not required.

QUESTIONS:

This RFI seeks responses from industry regarding technological tools that may improve HHS-RADV accuracy and efficiency and promote continued confidence in the program. The feedback from this RFI may be used to develop future RFPs.

CMS asks that respondents address the questions that are germane to your experience and expertise. Respondents are not required to answer all questions. CMS may request demonstrations following review of responses.

Technical Feasibility:

1. What functionality can be delivered within 6 months of award that accomplishes some resource reduction, then in later phases, scaled upward, achieving greater resource efficiency?

2. What is the offeror’s timeline for these deployment phases?

3. Please provide a reference architectural diagram of the offeror’s proposed ICAT solution.

4. Please describe interfaces with our Salesforce instance, called the CCIIO Customer Service Response Management System (CCRMS) proposed with ICAT. Please describe any other CMS system needs or dependencies.

5. Please provide the ICAT solution FEDRAMP authorization (High, Medium, or Low) including the hosting platform, software platform, or other 3rd party dependencies.

Operations and Maintenance:

6. What adoption, staffing and other factors permit for a positive CMS ROI over your proposed timeline?

7. What training should be included in this scope for effective user adaption?

8. Please provide a cost projection and a one- to five-year ROI estimate that identifies expected costs, expected savings, cost avoidance, payback period, and break-even point using proposed ICAT costs as the benchmark. Do not include CMS SVA costs in this analysis. Include one-time implementation costs, recurring license/subscription costs, Salesforce/CCRMS integration costs, cloud or compute costs, OCR/NLP/LLM/API costs, O&M costs, training costs, security and support costs, and help desk or user support costs.

Acquisition Strategy:

9. Describe your organization’s interest and ability to support an acquisition strategy in which CMS may award separate contracts for products, and services, and require all contractors to collaborate under Government-defined coordination and processes.

10. Should CMS consider using a multiple-contract structure rather than a single IDIQ or BPA approach?

11. For a multiple-contract structure, what layers/roles would you recommend CMS consider?

12. Describe your willingness to participate in a CMS-defined demonstration using synthetic or de-identified RADV-like records. Identify what functionality can be demonstrated live, what requires a sandbox, and what evidence CMS should request to compare solutions fairly. CMS may schedule demonstrations during the summer and fall of 2026.

Conflict of Interest:

13. In RFI #1, CMS stated any ICAT solution must meet be free of conflicts of interest as discussed, the regulatory citation 45 CFR § 153.630(b)(3):

Upon conducting market research, we are concerned the application of this standard may limit the availability of commercial products thereby undermining the ICAT goal of a 6-month initial deployment. We solicit comment on this question. Question 13 is not subject to the 3,000 limit to provide opportunity for a robust discussion.

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REQUEST FOR INFORMATION - Intelligent Coding Assistance Tool

Agency/Office:

Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) Centers for Consumer Information and Insurance Oversight (CCIIO) Payment Policy & Financial Management Group (PPFMG)

Project Title: HHS-Operated Risk Adjustment Data Validation Program (HHS-RADV) Intelligent

Coding Assistance Tool (ICAT)

Response Date: Wednesday, December 17, 2025 at 11am EST

1. BACKGROUND: The purpose of HHS-RADV is to promote confidence in the risk adjustment program set forth in Section 1343 of the Patient Protection and Affordable Care Act (ACA) by validating the integrity and quality of data provided by issuers via External Data Gathering Environment (EDGE) servers for the purpose of operating the risk adjustment program in state market risk pools where HHS operates the risk adjustment program. The HHS-RADV audit for a benefit year begins almost immediately following the data submission deadline for that benefit year. For example, the risk adjustment data submission deadline for the 2024 benefit year was April 30, 2025. HHS-RADV samples for the 2024 benefit year audit were generated in May 2025. The 2024 benefit year HHS- RADV results will be reported in June 2026 and HHS-RADV adjustments to the 2024 benefit year risk adjustment transfers will be reported in July 2026.

The six stages of HHS-RADV are:

1. Sample Selection;

2. Initial Validation Audit (IVA);

3. Second Validation Audit (SVA);

4. Error Estimation;

5. Appeals; and

6. Payment Adjustments.

CMS requires issuers to hire an independent auditor (IVA Entity) to conduct the IVA on a sample of enrollees’ risk adjustment data (most commonly, 200 enrollees with risk adjustment diagnoses per issuer). The IVA includes enrollment & demographic validation, prescription drug category (RXC) claim validation, and health status validation via medical chart/record review and diagnosis abstraction for the sampled enrollees. CMS requires that issuers provide IVA Entities with all source system information required to validate risk adjustment data. The IVA Entities are required to conduct the IVA, in accordance with CMS-established requirements, to verify the accuracy of issuer-submitted risk adjustment data. The IVA typically runs from May-January.

CMS contracts with the second validation audit entity (SVA Entity) to conduct a second level review and oversight of the findings from the IVA. The goals of the SVA are to confirm issuer compliance with the risk adjustment program and HHS-RADV requirements, verify IVA findings, and compute an estimate of issuer-level error in accordance with CMS requirements. For benefit years 2014-2023, the SVA reviewed a sub-sample of enrollees, starting with 12 and then moving to 24, 50, 100 or full sample re-review (i.e., 200) enrollees if statistical differences were determined between the IVA and SVA results.

To further enhance the accuracy and applicability of HHS-RADV results used to adjust issuers’ risk scores and ultimately transfer payments under risk adjustment, CMS increased the initial SVA review subsample size to begin at 24 and implemented statistical changes to the Pairwise Means Test beginning with the 2024 benefit year of HHS-RADV which, taken together, will result in a significant increase in medical charts/records reviewed in the SVA (see the 2025 Payment Notice (90 FR 4424) for more detail).

Further, with the increased subsample sizes, CMS has not changed the timing of HHS- RADV program execution (SVA review running from January through March with results published between May-July).1 Therefore, these changes may necessitate the use of innovative and technology-driven solutions to complete review activities within CMS’ specified timeline, thus this RFI.

For more details on the requirements of the HHS-RADV process, please see 45 CFR

153.630 and the 2024 Benefit Year HHS-RADV Protocols.

2. SUMMARY: The Centers for Medicare & Medicaid Services (CMS) is issuing this Request for Information (RFI) as a means of conducting market research to determine the availability and potential technical ability to procure a tool that is compatible with or integrated within Salesforce that consolidates from various sources discrete medical chart/record values for diagnosis abstraction. This tool should be able to populate the initial review template after accounting for HHS-operated risk adjustment and medical chart/record review requirements. Specifically, this tool will facilitate SVA primary coders and HCC validation. Please see the above 2024 RADV protocols for additional information. CMS intends to use this tool to facilitate enhanced and more accurate first-level medical chart/record review and diagnosis abstraction for the HHS-RADV program, specifically as part of the second validation audit (SVA) (see 45 CFR 153.630).

CMS is evaluating the appropriate ICAT from a wide range of commercial off-the-shelf (COTS) products, open-source solutions, and artificial intelligence (AI) options from various vendors and research institutions. Our primary goals are:

a. Reduce the time for medical coders to reach accurate conclusions for SVA

1 See the 2023 Benefit Year HHS Risk Adjustment Data Validation (HHS-RADV) Results Memo at https://www.cms.gov/files/document/by2023-hhs-radv-results-memo.pdf for an example of summary-level medical coding results and findings provided by CMS.

decisions.

b. Facilitate the review of medical charts/records more quickly than and as accurately as a human medical coder, notating and synthesizing relevant diagnostic information within the medical chart/record, and identifying relevant sections of medical chart/record and diagnosis codes with the same accuracy as or better than a human medical coder;

c. Reduce burden and CMS costs associated with hiring medical coders to complete HHS-RADV, specifically the SVA portion of HHS-RADV;

d. Improve efficiency and performance through progressive use and correction; and

e. Demonstrable and achievable financial and functional return on investment (ROI) within a reasonable timeframe (i.e., tool cost and necessary re-reviews result in savings compared to hiring additional human medical coders for the same workload and same accuracy).

Under 45 CFR § 153.630, a senior reviewer must confirm any enrollee risk adjustment error discovered during the initial validation audit (IVA). For purposes of this section, a “senior reviewer” is a human reviewer certified as a medical coder accredited by a nationally recognized accrediting agency who possesses at least 5 years of experience in medical coding. CMS therefore will likely restrict this tool to first-level review, but we welcome discussion (pros and cons) regarding potential use cases during “senior review” in later sections of this RFI.

3. Parameters and Restrictions

i. Salesforce:

This RFI is seeking solutions to be deployed in—or interact seamlessly with—our Salesforce instance called the CCIIO Customer Service Response Management System

(CCRMS).

CCRMS contains several Salesforce organizations and is controlled under a single Authority To Operate (ATO). PPFMG customized Salesforce to monitor stakeholder outreach workflow and inquiry response, and to provide reporting, data analysis, discrepancy identification, appeals tracking, data collection and reconciliation processes, and the HHS-RADV Audit Tool.

The HHS-RADV Audit Tool is where IVA Entities and issuers submit medical charts/records for SVA review. The HHS-RADV Audit Tool also ingests emails from CMS resource mailboxes for tracking purposes, ingests issuers’ HHS-RADV samples from EDGE data, generates sample enrollee packages (medical records and other documents) for SVA review, ingests SVA findings via SVA data entry forms, performs diagnosis coding mappings to HHS risk adjustment hierarchical condition categories (HCCs), calculates HCC failure rates, recalculates risk scores based on HHS-RADV findings, calculates HHS-RADV error rates, and performs email notifications and reporting. This tool requires ongoing code updates, security documentation updates, and annual Security Control Assessment (SCA) work performed through CMS FISMA Controls Tracking System (CFACTS). Any proposed ICAT solution must meet stringent privacy and security requirements associated with the handling of and storage of personal health information and privacy.

ii. Conflict of Interest

Any proposed ICAT must meet strict conflict of interest standards. Below are the current HHS-RADV standards which apply to issuers and their contracted IVA Entity but are also considered when CMS is contracting with an SVA Entity (see 45 CFR 153.630(b), HHS Notice of Benefit and Payment Parameters for 20152 and HHS Notice of Benefit and Payment Parameters for 2022,3 and the applicable benefit year HHS-RADV protocols).

CMS uses the same criteria issuers must use in evaluating their contracted IVA Entity when CMS determines that the SVA Entity, and any contractor supporting CMS’ SVA activities, is reasonably free of a conflict of interest such that it is able to conduct the SVA in an impartial manner and its impartiality is not reasonably open to question.

To demonstrate that the SVA Entity or any contractor supporting SVA activities is reasonably free of conflicts of interest, the SVA Entity must not have or previously have had a role in establishing any relevant internal controls of an issuer related to risk adjustment or the EDGE server data submission process and must not have served in any capacity as an advisor to an issuer regarding the risk adjustment or EDGE server data submission for the applicable benefit year for which the SVA Entity or SVA contractor is performing the SVA. Additionally, CMS expects that the SVA Entity or any contractor supporting SVA activities must not have or previously have had a role in establishing any relevant internal controls of an IVA Entity or issuer related to the HHS-RADV process or risk adjustment EDGE data submission process and must not have served in any capacity as an advisor to an IVA Entity or issuer regarding the HHS-RADV process or risk adjustment EDGE data submission process for the applicable benefit year for which the SVA Entity or SVA contractor is performing the SVA.

CMS has also defined conflict of interest standards between an issuer and IVA Entity, which CMS requires the issuer to use when evaluating an IVA Entity’s potential COI with the issuer, as described in the 2015 Payment Notice4 and 2022 Payment Notice.5For example, an IVA Entity is considered free of conflicts of interest if the following requirements are satisfied:

Neither the IVA Entity nor any member of its management team or data validation audit team (or any member of the immediate family of such a member) may have any material financial or ownership interest in the issuer, such that the financial success of the issuer could be reasonably seen as materially affecting the financial success of the IVA Entity or management team or audit team member (or immediate family member) and the impartiality of the IVA process could reasonably be called into question, or

2 See 79 FR at 13758.

3 See 86 FR at 24197-24198.

4 See 79 FR at 13758.

5 See 86 FR at 24197-24198.

such that the IVA Entity or management or audit team member (or immediate family member) could be seen as having the ability to influence the decision-making of the issuer. Immediate family is defined as a person’s smallest family unit, consisting of the closest relatives, such as parents, siblings, and children.

Neither the issuer nor any member of its management team (or any member of the immediate family of such a member) may have any material financial or ownership interest in the IVA Entity, such that the financial success of the IVA Entity could be seen as materially affecting the financial success of the issuer or management team member (or immediate family member) and the impartiality of the IVA process could reasonably be called into question, or such that the issuer or management team member (or immediate family member) could be reasonably seen as having the ability to influence the decision making of the IVA Entity.

Owners, directors, and officers of the issuer may not be owners, directors, or officers of the IVA Entity and vice versa.

Members of the data validation team of the IVA Entity may not be married to, in a domestic partnership with, or otherwise in the same immediate family as an owner, director, officer, or employee of the issuer.

Third Party Administrators (TPAs) or any organization/company/entity responsible for reviewing, analyzing, submitting claims or supplemental diagnosis records on behalf of an issuer via their EDGE server for risk adjustment calculation are considered to have a COI and may not be designated as an SVA Entity.

This technology will be utilized by the SVA Entity, so all respondents to this RFI must disclose any relationship (ownership, financial, other) to any IVA Entity or issuer.

Any ICAT potential solution(s) will need to meet these requirements. No ICAT solution owned by health insurance issuers or IVA Entities will be accepted.

4. High-Level Proposed Data Flows/Processes:

The following are high-level functions, data flows, and processes CMS is exploring to further enhance the accuracy and efficiency of the HHS-RADV program.

CMS is seeking creative ways for the ICAT to achieve our primary goals stated above;

however, we anticipate any proposed ICAT will support the following functionalities:

CMS will be able to design, update (based on user acceptance testing), and refine a data

“template” or first level SVA sub-sample enrollee review data synthesis.

The template will be populated by the ICAT using data scraped from multiple medical charts/records reviewed for the IVA and submitted to the HHS-RADV Audit Tool and other data stored within various areas of the HHS-RADV Audit Tool.

Ability to create multiple templates based on CMS need (i.e., HHS-RADV review template, SVA data entry form, SVA Findings, or Request for Reconsideration template).

Ability to “scrape” multiple data sources within the HHS-RADV Audit Tool including, for example, diagnosis terms extraction, other supporting evidence, and ICD-10 code mapping.

Ability to reconfigure required data elements based on CMS input.

Ability to flag non-conforming or non-valid data inputs for remediation.

Ability to make distinctions based on medical context and temporal reasoning (before, after, in-between, etc.).

Ability for reviewers to see source input from data stored inside the HHS-RADV Audit

Tool.

Those data sources will and can be provided in multiple formats including but not limited to: PDF, Excel, Word, JSON, and XML formats.

Validations of data input.

Error rate measurement and ability to see which medical codes were extracted by the

ICAT.

Validation that medical records are signed by appropriate signing agent (e.g., credentialed provider licensed to diagnose health conditions).

Validation that scraped information is gathered from HHS-RADV allowable sections of the medical record.

Validation that medical records are for the sampled enrollee (e.g., correct name, sex, and date of birth) and match to dates of service on the linked claim.

All ICAT proposed solutions must meet strict FISMA requirements.

Additional Features

Generate scheduled and ad hoc reports at CMS’ request.

Ability for CMS and contractor teams to evaluate the ICAT findings and error rates, by data source and data element and against human error rates.

5. RESPONDING TO THIS REQUEST:

THIS IS A REQUEST FOR INFORMATION (RFI) ONLY. This RFI is issued solely for CMS’ information and planning purposes. This RFI does not constitute a Request for Proposal (RFP) or a promise to issue an RFP in the future. This RFI does not commit the Government to contract for any supply or service. At this time, CMS is not soliciting quotes/proposals. Respondents are advised that the U.S. Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the respondent’s expense. Not responding to this RFI does not preclude participation in any future procurement. It is the responsibility of the interested vendors to monitor this site for additional information pertaining to this requirement. Information provided in the RFI is subject to change and is not binding on the Government. HHS, CMS, or OAGM have not made a commitment to procure any of the items discussed, and release of this RFI is not a commitment or an authorization to incur cost for which reimbursement would be allowed or sought.

Proprietary information and trade secrets, if any, must be clearly marked on all materials. All information received in response to this RFI that is marked “Proprietary” will be handled accordingly. Please be advised that all submissions become Government property and will not be returned, nor will the receipt be confirmed. Respondents will not receive feedback on their submission. No basis for claims against the United States Government shall arise as a result of a response to this RFI or from the United States Government’s use of such information.

Responses to this RFI shall be submitted no later than 11am local prevailing time on Wednesday, December 17, 2025 to Malissa Shin, Contracting Officer, at Malissa.Shin@cms.hhs.gov and Megan Famodu, Contract Specialist, at Megan.Famodu@cms.hhs.gov, in a format that is readable in Microsoft Word or Adobe PDF document with page size 8.5 by 11 inches, with a minimum of 1” margins. Calibri Font Size 11 with no less than single spacing between lines is required.

Please note that a response to every question is not required. Responses will be no more than 10 pages in total and no more than 2,000 characters per question. CMS will not accept hard-copy responses or other formats. All responses to the RFI shall contain ‘HHS-RADV- ICAT RFI – Company Name’ in the response email's subject-line.

Section I. – General Vendor Information: General Vendor Information to include the following:

Organization Name Mailing address Name, phone number, and e-mail address of designated point of contact Business type (large business, small business, small disadvantaged business, 8(a)-certified small disadvantaged business, HUBZone small business, woman-owned small business, very small business, veteran-owned small business, service-disabled veteran-owned small business).

Any current or previous federal contracts in the GSA, Governmentwide Acquisition Contracts (GWAC), or any other relevant federal contracts held by your organization.

Section II. The name and contact information of the organization whose views are represented in the submission, if different from the information provided in Section I.

Section III. Respondents are encouraged to provide complete but concise responses to the questions listed below. Please note that a response to every question is not required.

QUESTIONS:

This RFI seeks responses from industry regarding technological tools that may improve HHS- RADV accuracy and efficiency and promote continued confidence in the program. The feedback from this RFI may be used to develop future RFPs.

CMS asks that respondents address the questions that are germane to your experience and expertise. Respondents are not required to answer all questions.

ICAT Questions

1. What functionalities would constitute a minimum viable product for this ICAT?

2. What ICAT functions should be prioritized in a phased development and implementation process for immediate impact?

3. What parameters or functionalities (if any), outlined in Section 3, are too prescriptive and why?

4. What (if any) are the limitations of deploying this ICAT within Salesforce?

5. How can CMS best create auditing and compliance records?

6. What are the best use cases for this ICAT in the first-level medical record review?

7. What are the best use cases for this ICAT in the Senior medical record review?

8. What are the pros and cons of restricting this ICAT to first-level medical record review?

9. How can this ICAT help CMS during SVA Findings, Discrepancies, Requests for Reconsideration, or other administrative and federal appeals?

10. What considerations and transaction components should CMS consider in transaction flows for data exchange?

11. What are the pros and cons of restricting data input/ICAT review file types? Are there additional file types that should be required?

12. CMS seeks to evaluate a broad array of commercial-off-the shelf (COTS) products, large language models (LLMs), and Agentic Technology from various firms. What type of tool is best suited for the above requirements and why?

13. What experience does your organization have with the proposed best suited ICAT?

14. What are the best suited metrics to measure error rates (human and technology), and to ensure a return on investment for this technology?

15. What is the best suited contractual vehicle for this type of development and why?

16. What experience does your organization have with applicable federal laws and regulations involved with the handling of Personal Health Information (PHI), Personal Identifiable Information (PII), and IT security standards such as the Federal Information Security Management Act of 2002?

17. Does your organization have any current relationship(s) with CMS initiatives?

Contract Specialist

Megan Famodu

Email: Megan.Famodu@cms.hhs.gov

Contracting Officer

Name: Malissa Shin

Email: Malissa.Shin@cms.hhs.gov