Ep. 97 – AI and Your Employees

On this episode of The Healthcare Compliance Pod, we kick off a three-part series on artificial intelligence, specifically designed for smaller healthcare providers. Over the next three weeks, we will discuss basic policies and processes small providers should adopt as it relates to AI use within their organizations.

This week’s focus? Employees.

Update Your Employment Policies

At a bare minimum, every healthcare provider should incorporate basic AI provisions into their employment policies, including the employee handbook and acceptable use policy. These updates don’t have to be complicated. In fact, they’re relatively straightforward.  

Your policies should clearly state that employees may not use AI tools that have not been pre-approved by the organization for the intended use, and approved AI tools should not be used for unapproved purposes. You should also explain how an employee may obtain prior approval before using any AI tool or expanding the use of a pre-approved AI tool. Finally, employees should be informed that confidential and other proprietary or non-public company data should not be shared with or uploaded into AI tools unless the organization has approved the sharing of data and has appropriately vetted the AI tool, and ensures the appropriate agreements, if applicable, are in place with the vendor.

Understand and Articulate Your AI Approval Process

Before rolling out these updates, you must determine:

• Who approves AI use?
• What is the review process?
• Who vets AI technology?
• How will usage be monitored?

For a small organization, this might mean routing requests through one designated person. For a larger group, it could involve supervisors plus IT, compliance, an HR review, or even forming an AI committee.

Whatever the structure, make it simple for employees to initiate and make sure they are aware of how to request approval and the process used by the organization to review the request.

To ensure the approved AI tool is used appropriately and as intended within the organization, each approval should clearly define:

• Who may use the tool?
• What tool is approved?
• What data can be entered?
• What restrictions apply?
• Monitoring cadence (e.g., every six months)

Meet With Employees About AI Policies

Simply updating your policies is likely insufficient to gain buy-in and compliance from your employees. Employees need to understand why the policies exist. These meetings can also help you gain insight from employees into how they perceive AI as being useful for their job functions and how they may already be using AI in their day-to-day tasks. You can also use these meetings to reinforce that the organization is not “anti-AI” but desires to ensure that any use is appropriate and does not create risk to patients and the organization.

Make AI an Ongoing Conversation

AI is evolving rapidly. Regularly update employees on:

• What AI tools are approved
• What the organization is evaluating
• Industry developments
• Feedback from clinical teams

Employees are curious. Many may already be comfortable, or even somewhat reliant, on AI tools from prior workplaces or educational settings. Engaging them helps your organization stay informed and competitive while managing risk responsibly.