State Regulators Address Insurers’ Use of AI: 11 States Adopt NAIC Model Bulletin

By and on June 25, 2024

In December 2023, the National Association of Insurance Commissioners (NAIC) adopted a Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers. The model bulletin reminds insurance carriers that they must comply with all applicable insurance laws and regulations (e.g., prohibitions against unfair trade practices) when making decisions that impact consumers, including when those decisions are made or supported by advanced technologies, such as AI systems. To date, 11 states have adopted the model bulletin, thereby applying the standards to insurers that operate in the states.

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Gregory Mitchell
Greg Mitchell works with healthcare payors and providers to meet the full spectrum of their managed care and reimbursement arrangement needs. He helps managed care organizations, third-party administrators, independent practice associations, risk-bearing entities, management services organizations, hospitals and health systems, digital healthcare providers, and other organizations both large and small negotiate and draft a range of managed care and value-based agreements. Greg has experience with a variety of arrangements and models, including fee-for-service, bundled payment, shared savings and shared loss models, gainsharing and capitation arrangements. Read Greg Mitchell's full bio.


Emily Curran
Emily R. Curran focuses her practice on healthcare regulatory and compliance issues in the managed care space. She counsels both for-profit and non-profit healthcare insurance companies on state and federal policy issues and advises clients on reimbursement issues that come into play when participating in government healthcare programs. Emily also supports the Firm’s transactional work. Read Emily Curran's full bio.

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