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 Supervision of AI #

Obligation:
Human Oversight
enforcing
Effective:
Jan 1, 2025
Risk tier:
high-risk
Scope:
health care service plans, disability insurers, and their contractors

Requirements

RequirementDetails
Physician-only determinationsOnly licensed physicians or qualified professionals may deny, delay, or modify services based on medical necessity — AI cannot make these calls
Clinical basisAI tools must base utilization review determinations on enrollee clinical history, provider circumstances, and medical records
Non-supplantingAI must not supplant provider decision-making in utilization review
Non-discriminationAI must be equitably applied and not discriminate
AuditabilityAI tools used for UR/UM must be auditable

Penalties

ViolationFine
Non-complianceCA Department of Insurance + AG enforcement
View full regulation View obligation Obligation matrix