We submit the following comments to support a regulatory framework that ensures patient safety while enabling responsible and equitable innovation.

Most evaluation frameworks focus on whether a model says the right thing when it encounters suicidal ideation. That’s a start, but it’s not enough. The evaluation needs to test what happens next: how the model uses tool calls to take action, route information, or trigger the right workflow. That’s what actually determines safety. 

New peer-reviewed research published in JMIR Formative Research confirms that Wave Life’s coaching-first model drives rapid, measurable improvements in anxiety, depression, and stress—often within 30 days. The study shows that evidence-based coaching can deliver clinically significant outcomes at scale, even for individuals with severe symptoms.

Learn why quick fixes don’t solve workplace stress and how a dedicated mental-health coach helps employees build lasting resilience, engagement, and wellbeing.

Most workplace mental health programs stop at access. True care navigation keeps employees supported, guided, and improving. Here’s how Wave builds it in from day one.

Coaching isn’t just for “wellness.” Learn how trained, supervised mental health coaches deliver real outcomes for high-symptom users and why employers and health plans should take note.

Learn how to measure mental health program success. Go beyond utilization and see why symptom tracking and outcomes prove real ROI.

Learn how Wave ensures coaching quality at scale with Coach U, clinical supervision, and outcomes-driven care to help employees feel better faster.

Employers don’t need a new vendor for every workforce health trend. See how Wave’s transdiagnostic coaching model adapts to menopause, GLP-1s, caregiving, and beyond—with outcomes that prove ROI.

Learn why most “personalized” mental health solutions fall short and what real personalization looks like for employees, health plans, and beyond.

Employee mental health spans stress to chronic conditions. Learn why flexible, personalized support models outperform one-size-fits-all approaches.

Most coaching platforms rely on gig workers with no standards. Wave’s Coach University develops NBHWC-certified coaches through rigorous training, clinical supervision, and a proven transdiagnostic model—driving engagement, outcomes, and ROI.

Wave replaces lagging, utilization-only EAP reporting with continuous outcomes tracking that proves ROI and drives employee wellbeing.

Traditional EAPs have 2–5% engagement. Coaching is 5x higher. Here’s why employees avoid EAPs—and how Wave fixes the problem.

Employers are investing in mental health coaching. But not all coaching is created equal. Learn what separates high-quality coaching from generic wellness apps and how Wave sets the standard.

Traditional EAPs track usage. Measurement-based care tracks outcomes. Discover why that distinction matters—and how Wave proves ROI for your mental health benefits.

AI in mental health is booming, but can you trust it? Learn how Wave combines AI and human care to deliver real outcomes, safely and at scale.

Wave supports menopause, GLP‑1s, neurodiversity, and more with one scalable care model that adapts as health trends evolve—no extra vendors required.

Whole-person mental health is more than a buzzword. Learn what it really means, why traditional EAPs fall short, and how Wave’s coaching-first model delivers measurable ROI.