AHCA/NCAL Responds to Federal Request on AI in Healthcare
The American Health Care Association and National Center for Assisted Living (AHCA/NCAL) has recently submitted a comprehensive set of comments to the Assistant Secretary for Technology Policy and the Office of the National Coordinator for Health Information Technology (ASTP/ONC) within the U.S. Department of Health and Human Services (HHS). This response was crafted to address a request for information (RFI) titled Accelerating the Adoption and Use of Artificial Intelligence in Clinical Care.
The RFI seeks public input on HHS strategies to encourage the responsible and effective integration of artificial intelligence (AI) into clinical care. It highlights crucial areas such as regulatory oversight, reimbursement models, and research and development priorities. In total, ten targeted questions were posed by ASTP/ONC to gather diverse perspectives from stakeholders across the healthcare spectrum.
Highlighting Challenges and Opportunities in Post-Acute Care
AHCA/NCAL’s submission reflected the unique insights and concerns of their providers, which include skilled nursing facilities (SNF/NF), assisted living (AL) communities, and homes serving individuals with intellectual and developmental disabilities (ID/DD). The association’s comments began by offering important context on the populations they serve, the current state of digital infrastructure, and historical barriers—financial, legislative, and regulatory—that have impeded the adoption of advanced technologies such as AI in these settings.
According to AHCA/NCAL, one of the primary obstacles to effective AI implementation is the fragmented nature of existing digital capabilities in long-term and post-acute care (LTPAC) facilities. Without substantial improvements in interoperability—the seamless exchange and use of electronic health information—these providers will continue to face significant challenges in leveraging AI for clinical care. The association emphasized that true functional interoperability is essential to provide the comprehensive, accurate information required for secure and effective AI use.
Key Recommendations for Accelerating AI Integration
In its comments, AHCA/NCAL outlined several critical recommendations to guide national policy and support the safe, equitable, and efficient adoption of AI in clinical settings, especially those serving older adults and individuals with complex needs. Among these recommendations were:
- Mandating age-stratified validation and bias testing for AI tools intended for Medicare populations. This ensures that AI solutions are effective and safe across diverse age groups and do not inadvertently introduce or perpetuate bias.
- Expanding interoperability standards to include important geriatric-specific data elements such as functional status, cognitive status, and social determinants of health. Incorporating these data points is crucial for tailoring AI applications to the needs of aging populations.
- Aligning payment policies to incentivize the adoption of high-value AI technologies in LTPAC environments. Appropriate reimbursement models can drive innovation and encourage providers to invest in transformative technologies.
- Providing infrastructure support and technical assistance to help under-resourced LTPAC providers prepare for AI integration. This includes funding, training, and access to essential technological resources.
- Prioritizing research funding for AI applications that address the most pressing challenges facing older adults, such as multimorbidity, functional decline, and other geriatric concerns.
- Establishing clear regulatory frameworks to address issues of liability, privacy, and algorithmic transparency, especially for AI tools that are not classified as medical devices.
- Creating validation testbeds and evaluation frameworks that specifically include LTPAC settings and older adult populations, ensuring that new technologies are rigorously assessed in real-world environments.
The Road Ahead for AI in Long-Term Care
AHCA/NCAL’s thoughtful response to the RFI reflects both the promise and the complexity of integrating artificial intelligence into clinical care for vulnerable populations. The association urges federal agencies to recognize the unique circumstances and needs of LTPAC providers, particularly regarding digital infrastructure gaps and the need for tailored policy solutions.
By implementing these recommendations, policymakers can help unlock the full potential of AI to improve quality, safety, and efficiency in long-term and post-acute care settings. AHCA/NCAL continues to advocate for approaches that prioritize patient well-being, provider readiness, and the equitable distribution of technological benefits.
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