Staff are already experimenting with AI tools. Without guidance, someone will paste patient information into a consumer chatbot. A short, clear policy tells people what is allowed, protects patients, and gives the practice a record of reasonable governance.
If a vendor creates, receives, maintains or transmits PHI for you, a business associate agreement is typically required. Safeguards, minimum necessary use and access controls apply. Start with the HHS HIPAA for Professionals pages and involve your privacy officer or counsel. This article is general information, not legal advice.
Hold a thirty-minute staff session with real examples of allowed and not-allowed uses. Name one owner. Review the approved-tools list quarterly. Revisit after any new tool is proposed.
Illustrative scenario, not a client result: the numbers below are made up to show the method.
A practice approves one writing assistant for non-clinical tasks such as drafting a newsletter, policy templates and website copy, with the rule that no patient information may be entered. A separate approved scheduling assistant has a signed agreement and access limited to scheduling data. Anyone who wants to try a new tool submits a short request to the owner, who reviews privacy terms before approving.
| Tool | Allowed uses | Never enter | Owner | Review date |
|---|---|---|---|---|
| Writing assistant (example) | Drafting newsletters, website copy, policy templates | Patient names, identifiers, clinical details | Practice manager | Quarterly |
| Scheduling assistant (example) | Appointment reminders and rescheduling | Clinical notes | Front desk lead | Quarterly |
| Call assistant (example) | After-hours FAQs and message capture | Symptom assessment or advice | Practice manager | Monthly in pilot |
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Create a no-blame reporting path. If PHI may have been entered into an unapproved tool, stop use, notify your privacy officer immediately, and follow your breach assessment procedures and applicable law. Document what happened and update training. Quick, honest reporting is the best protection.
Review at least annually and whenever you add a tool, a new use case or a vendor change. Keep a version history and the date staff last completed training.
| Role | Responsibility |
|---|---|
| Practice leadership | Approves the policy and the approved-tools list |
| Privacy or compliance officer | Reviews vendors, agreements and incidents |
| Practice manager | Owns day-to-day questions, training and register updates |
| All staff | Follow the policy, review AI output, report mistakes |
| Clinicians | Remain responsible for clinical decisions; AI output never replaces judgment |
Plain language works best. Adapt and have counsel review text such as:
| Use case | Typical risk | Suggested handling |
|---|---|---|
| Drafting a newsletter or blog outline | Low | Approved tool, human edit, fact-check |
| Summarizing a public regulation | Low to medium | Verify against the source |
| Drafting patient reminders | Medium | Approved template, no clinical details, compliance review |
| Answering patient calls or chats | Medium to high | Strict scripts, hand-offs, vendor agreement, monitoring |
| Summarizing visit notes | High | Only in a tool approved for PHI with agreements, clinician review |
| Suggesting diagnoses or treatments | Very high | Not permitted without formal clinical governance |
Put review dates on the calendar: quarterly for the approved-tools register, annually for the policy text and training. Record changes, keep the signed acknowledgment from each staff member and retire tools that are no longer used. A policy that is read, understood and updated protects patients far better than a long document nobody opens.
If anyone on the team might use AI tools, yes. A short policy reduces the risk of patient information being entered into unapproved tools.
Not into any tool that is unapproved or not covered by appropriate safeguards and agreements. Your policy should say this plainly.
If a vendor handles PHI on your behalf, a BAA is typically required. Confirm with counsel or your privacy officer.
One page is enough to start. Add detail only where staff have questions.
No. It is a general starting outline. Have qualified counsel review your final policy.
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