In an article published in Law360, Healthcare Department Co-Chair Bryant Godfrey and Holon Law Partners’ Jashaswi Ghosh wrote about Utah’s partnership with Doctronics, a pilot program that would allow an AI system to renew certain prescription medications without direct physician involvement.

The pilot program, the first of its kind in the U.S., is limited to select commonly prescribed maintenance medications, all reviewed and approved by the state and independent pharmacists. It will include multiple layers of physician oversight and has been framed as an experimental policy approach aimed at removing a bottleneck to healthcare rather than a deregulatory action. 

However, the article points out significant concern from physician organizations and consumer advocates, which ranges from warnings that AI-driven patient self-reporting may not capture the full scope of a patient’s condition, to warnings that AI-based prescription renewals “blur the distinction between licensed medical professionals and software applications” with “the potential to mislead patients and undermine established norms of medical accountability.” The authors note, however, that the FDA has declined to comment, maintaining that the program currently falls outside its regulatory purview. 

The article suggests state and national medical boards are likely to analyze the Utah program through the lens of the Federation of State Medical Boards’ guidance, which “emphasizes that clinical responsibility must remain clearly attributable to a licensed physician, even where AI tools are used extensively in care delivery.”

Looking forward, “the program's significance lies less in its immediate clinical impact and more in its function as a test case for how regulators may draw boundaries between administrative automation and medical judgment.” Furthermore, “it also underscores the need for careful governance, clear accountability and sustained human oversight as AI systems move closer to the core of medical practice.”

Read the full article here.