Does California SB 1120 (Physicians Make Decisions Act) require Human Oversight?
California • enforcing
Yes — 1 provision
Requirements at a glance
This regulation imposes 5 specific requirements for Human Oversight across 1 provision:
- Physician-only determinations — Only licensed physicians or qualified professionals may deny, delay, or modify services based on medical necessity — AI cannot make these calls
- Clinical basis — AI tools must base utilization review determinations on enrollee clinical history, provider circumstances, and medical records
- Non-supplanting — AI must not supplant provider decision-making in utilization review
- Non-discrimination — AI must be equitably applied and not discriminate
- Auditability — AI tools used for UR/UM must be auditable
Physician Supervision of AI #
Requirements
| Requirement | Details |
|---|---|
| Physician-only determinations | Only licensed physicians or qualified professionals may deny, delay, or modify services based on medical necessity — AI cannot make these calls |
| Clinical basis | AI tools must base utilization review determinations on enrollee clinical history, provider circumstances, and medical records |
| Non-supplanting | AI must not supplant provider decision-making in utilization review |
| Non-discrimination | AI must be equitably applied and not discriminate |
| Auditability | AI tools used for UR/UM must be auditable |
Penalties
| Violation | Fine |
|---|---|
| Non-compliance | CA Department of Insurance + AG enforcement |