Health systems should prepare now for increasing enforcement around AI use

Regulatory enforcement around healthcare AI is nascent but will intensify, warns Jeff Wurzburg, healthcare partner at Norton Rose Fulbright. He predicts that oversight will evolve through existing payment and supervisory frameworks — for example, billing audits and established health oversight mechanisms — rather than through creation of an AI-specific regulator. The shift signals growing legal and financial risk for health systems that deploy AI-enabled clinical and administrative tools without robust controls.

Health systems should proactively strengthen governance, vendor due diligence, model validation, documentation and compliance programs to withstand increased scrutiny. Preparation should include contract clauses, audit trails, performance monitoring, training and alignment with payment rules to reduce exposure to enforcement actions. Wurzburg’s guidance frames AI readiness as an operational and legal priority as regulators adapt current enforcement tools to AI use in healthcare.

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