Introduction
Federal agencies within the United States government issue Requests for Information (RFIs) to gather input on a range of topics from strategic plans to changes to existing policies. Developing thoughtful responses to RFIs is a time-intensive process. It is therefore essential for organizations to understand how to do so as efficiently and effectively as possible. To aid in this process, AcademyHealth reviewed its impact on past RFIs and conducted interviews with federal officials who process RFIs. This blog post summarizes takeaways from these interviews and provides guidance on best practices for responding to RFIs.
Methods
In Autumn 2023, the AcademyHealth advocacy team conducted informational interviews with federal officials across several agencies that have processed HSR-relevant RFIs. All interviews were recorded, transcribed, and evaluated for thematic content. Key themes and takeaways are presented below.
Agency processes for reviewing and evaluating RFI responses.
The process for reviewing RFI responses varies across and within agencies. RFIs serve various purposes, from guiding funding decisions and strategic plans, to sharing knowledge with the stakeholder community. Additionally, whether an RFI is part of a rulemaking vehicle versus a standalone RFI also affects the process and evaluation; for rulemaking, the priority is to finalize what was proposed in a rule and comments are summarized and saved, while a standalone RFI is often, but not always, intended to inform more immediate action.
Even with this variation, some form of qualitative analysis is often used to analyze the responses. Agency staff or contractors manually complete most of this work. Sorting software is sometimes utilized for larger responses, in which case keywords that can be detected by algorithms may be important.
The evaluation process consists of identifying themes within the data. However, agencies are not simply seeking to tabulate the number of responses supporting a theme. Instead, they are interested in the arguments organizations make to support their recommendations and how they intersect with other perspectives.
Prioritization of stakeholder input and suggestions
There are not necessarily specific factors that hold more weight when processing RFIs, and prioritization is again contingent on the purpose of the RFI. Some of factors positively affecting whether a response is prioritized include: recurring themes, direct experience, novel ideas, and thoughtfulness of the response.
Agencies often prioritize recurring themes to gauge consensus on the importance of a topic. Hearing similar themes from multiple organizations but with slightly different angles is seen as an indicator the agency should consider that recommendation. Depending on the RFI, agencies may prioritize hearing from those with direct experience on a topic (e.g., those working on the front line, patients, direct stakeholder involvement, etc.).
RFI Response Best Practices
- Provide direct, actionable recommendations within an agency’s authorization.
Organizations should provide direct, actionable recommendations that are within an agency’s authorization. If recommendations are not within the agency’s authority, such as conducting research when they are not authorized to do so, and/or are overly broad, they likely will not be usable. Therefore, researchers and organizations should consider crafting their responses along the lines of, “Within the framework of the statute, here are some specific actions you might want to take,” rather than providing big picture summaries.
- Supply evidence and information tailored to the RFI, especially if this is difficult to obtain.
The types of evidence and supporting information agencies find most valuable in an RFI are contingent on the nature of the RFI. For example, RFIs focused on patient-centered outcomes, should include patient perspectives when developing comments. The perspectives of those with other direct experience (e.g., providers, etc.) may also be useful. Organizations should consider how their membership can offer insights related to the specific needs of the RFI.
Some agencies value heavily cited documents with detailed information and substantiating evidence. Where possible, organizations should cite research that can speak to the specific questions being asked (e.g., This study found that X will increase premiums by Y percent) rather than general support or statements (e.g., This will increase premiums).
Offering otherwise inaccessible internal information is particularly useful. This includes providing internal information about barriers to implementing a policy, or analyses that are not yet published.
Additionally, agencies value novel and creative suggestions. Commenters should consider proposing unique perspectives or solutions that the target audience may not have thought of and can execute.
Beyond answering the questions, it is appropriate to address topic areas that were not included in the RFI, but that the commenting organization thinks should be considered. Organizations could do so by including a statement such as, ‘In addition, although the RFI did not ask about this, you might consider…XYZ.”
- Highlight the organization’s unique perspective and refrain from having members submit identical responses.
Even if multiple organizations are aligned in their recommendations, agencies prefer that each organization responds to RFIs individually rather than signing onto a joint response. This is because agencies value the unique perspectives provided by each individual or organization. Therefore, organizations should first consider how their position is both similar and distinct from other groups. They should then craft their response based on their constituency and emphasize their specific angle, even if the overall recommendations are similar. Organizations should also refrain from having their individual members submit identical responses. Instead, to demonstrate a consensus, they can include a statement such as “We held X number of listening sessions with our constituency and Y many providers and the things that rose to the top were Z.”
- Maintain credibility by providing context.
Agencies consider the credibility of the information based on an organization’s reputation and conflicts of interest. Therefore, providing clear background information about who is providing the comment is helpful, but this should be concise.
- Ensure the document is well organized.
If there is more than one recommendation, organizations should ensure they are easy to discern. Utilize headings and group information in a way that is accessible and easy to follow.
- Indicate areas of support.
Organizations should provide feedback on the aspects of the RFI they support and why. For example, noting the elements of a strategic plan the organization endorses and any evidence that supports this stance. This can help agencies understand how best to move forward.
- Long-term engagement is preferable; immediate follow up is often unnecessary.
The type of follow-up preferred varies across and within agencies. In general, immediate follow-up is unnecessary and can be cumbersome to the process. If clarification is required, agencies will initiate contact.
Instead, organizations should consider avenues to stay engaged with the agency and build relationships over the long term. It may be appropriate to follow up after the RFI process is complete to express appreciation for incorporating specific recommendations and offer additional information or ways the organization can help.
- Ask for clarification.
Most RFIs have a point of contact listed. If there are questions about the process or content desired, the point of contact is there to offer guidance. Communicating with the agency outside of the point of contact is ineffective and can be counterproductive.
To learn more about the comments that AcademyHealth has made, click here. If there are RFIs that you think AcademyHealth should respond to, email us at Advocacy@AcademyHealth.org.