Thompson Examines HHS Artificial Intelligence Strategy in Law360 and The Legal Intelligencer

04.07.2026

Stinson LLP attorney Theodore Thompson authored articles examining the U.S. Department of Health and Human Services’ (HHS) adoption of artificial intelligence across its agencies. His analysis appears in both Law360 and The Legal Intelligencer, offering insights for legal, policy and vendor audiences on how HHS is implementing AI and what stakeholders need to know.

In Law360, Thompson explores HHS’ internal governance framework, including the establishment of an AI governance board and the acting Chief Artificial Intelligence Officer role. He notes that the department is applying the Office of Management and Budget’s memo M-25-21 to manage, monitor and, when necessary, halt high-impact AI projects, balancing the dual mandate of rapid innovation and risk management. Thompson emphasizes the operational challenges of implementing AI across agencies with diverse missions, such as the U.S Food and Drug Administration’s regulatory oversight and the National Institutes of Health’s research initiatives, highlighting the importance of leadership coordination and standardized compliance practices.

Thompson’s piece in The Legal Intelligencer focuses on implications for federal vendors, outlining how AI providers can align with the department’s “OneHHS” strategy to gain a competitive edge in government contracting. He outlines important considerations for vendors, including understanding risk management requirements, ensuring proper handling of data, and aligning solutions with departmental priorities. “Vendors who align their offerings with these strategic priorities—demonstrating transparency, interoperability, robust risk management, and American innovation—will be best positioned to serve the federal health mission,” Thompson notes.

Together, these articles provide a comprehensive view of HHS’ AI strategy, bridging the gap between internal agency governance and external stakeholder engagement. Thompson’s analysis underscores the significance of executive-level coordination, robust risk management, and strategic alignment for both agencies and vendors navigating the growing role of AI in federal operations.

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