Responsible AI & compliance

AI that goes both ways, shows its arithmetic, and holds up in an audit.

When software adds a diagnosis to a record and justifies a payment, "responsible" has to mean "defensible." This page is written for compliance officers, HIM directors, and auditors: what the engine does, what it refuses to do, and what you can export to prove it.

Why it matters now

Regulators are looking at AI-assisted revenue capture.

The context: enforcement commentary from healthcare law firms for 2025–2026 describes the Department of Justice and HHS-OIG connecting AI-driven chart review and coding tools to False Claims Act theories, and recommends human-in-the-loop safeguards plus documented accuracy and bias audits for any AI that touches documentation or coding. An engine that only ever moves the DRG up, with a black-box score and no audit trail, is exactly what that scrutiny is aimed at. We built Medically as the opposite.

What regulators are asking

Is a human accountable for every code? Can you show why a diagnosis was added? Is the tool biased toward higher reimbursement? Are its accuracy and drift monitored and documented?

What revenue-first AI gets wrong

Upgrade-only findings. Confidence scores nobody can reproduce. Free-text "dismiss" with no reason. One clinical definition for every payer. No record of which model version made the call.

What Medically does instead

Findings in both directions. A deterministic defensibility score with its arithmetic stored. Payer-specific criteria. Reason-coded decisions in an append-only ledger. An export an auditor can read.

The compliance-first engine

One system, not three features: criteria, two-way findings, score, ledger.

Payer-specific criteria drive a two-way AI pass over the chart. Every finding is gated on a verbatim, located quote. A deterministic scorer turns the stored facts into a defensibility score, and everything lands in an append-only ledger the compliance console reads from.

1

Payer criteria registry

Your hospital chooses which clinical definitions apply per payer: Sepsis-2 or Sepsis-3, ASPEN or GLIM malnutrition, KDIGO acute kidney injury, acute respiratory failure thresholds. Each set is versioned, so a finding always records which version it was judged against.

2

Two-way AI pass

The model reads the chart against the resolved criteria and proposes upgrades, unsupported diagnoses, and downgrades. A finding without a verbatim diagnosis statement and located counter-evidence is discarded, not shown. New finding types ship Off → Shadow → On.

3

Deterministic scorer + ledger

The AI posts findings and evidence — never a score. A scorer computes defensibility from the stored, located facts, so the same inputs always give the same number. Every disposition, reason code, and model version is appended to the finding's history; nothing is overwritten.

4

Compliance console

Open downside exposure in dollars, precision and acceptance by finding type, average defensibility of accepted versus dismissed findings, and a permission-gated OIG-ready export that carries evidence, criteria, score breakdown, disposition, and model and prompt IDs.

Precision and acceptance by finding type feed back to calibrate the engine. Your reviewers' decisions improve prioritization; they are never used to train models on your PHI.

The defensibility score

How likely is this diagnosis to survive clinical-validation review?

A 0–100 score on every finding, built from components a reviewer can check by hand. The breakdown is stored with the score, along with the scorer version, so a number can be reproduced months later.

Criteria met
How many of the payer's required and supporting criteria are satisfied by located evidence in the record.
up to 45
Evidence strength
Whether the support comes from objective results and orders (labs, imaging, medications) or only from narrative text.
up to 25
Consistency
Does the diagnosis appear consistently across notes, problem list, and treatment — or once, in one note?
up to 15
Counter-evidence
Located spans that argue against the diagnosis (a normal lactate, a resolved finding) subtract from the score — and are shown to the reviewer.
penalty
Absent required criterion
A criterion the payer treats as mandatory that is not documented at all.
penalty
Defensibility
Weak, moderate, or strong — with the arithmetic beneath it. Same inputs, same score, every time.
0–100
The AI never produces the score.The model proposes findings and cites verbatim spans. The score is computed in the platform from what was stored. Model rationale is displayed, labeled as not used in the score.
Payer-aware by construction.The same chart can score differently against Sepsis-2 and Sepsis-3. A payer selector re-runs the evaluation, and the criteria version is recorded with the result.
Downside is measured in dollars, too.A weak score on a documented diagnosis is a denial waiting to happen. The worklist shows the exposure at risk alongside upside, so the compliance view and the finance view are the same list.
It calibrates against outcomes.Acceptance, query outcomes, and later denials are tracked per finding type, so you can see whether accepted findings really do score higher than dismissed ones.
Model governance

How the models are bounded, versioned, and watched.

Human in the loop, every time

  • No code, query, or appeal reaches the record or the claim without a credentialed person's sign-off
  • Accept, reject, and query each require a reason code; free-text dismissals are not accepted
  • Your own CDI team certifies findings, or our board-certified physician reviewers do when you need capacity

Never fabricate, never upgrade-only

  • A finding is gated on a verbatim diagnosis statement and located evidence; anything the model cannot quote is discarded
  • Upgrade, unsupported, and downgrade findings are produced by the same pass and ranked the same way
  • The platform recommends a lower code, level, or DRG when the record supports it

Versioned, shadow-tested, monitored

  • Model, prompt, criteria, and scorer versions are stored on every finding, so any decision can be reproduced
  • New finding types run in shadow mode first — scored and logged, not shown — so precision is measured before anyone acts on them
  • Bias and drift monitoring by finding type, payer, and service line; errors are graded by severity, not just counted

Documented for your governance committee

  • Precision and acceptance rates by finding type are published in your compliance console, not hidden in a sales deck
  • Model documentation — intended use, data policy, evaluation approach, known limitations — available to customers under NDA
  • We welcome independent validation by your internal audit team or a third party on your own charts
Your PHI and the models: the AI runs under enterprise agreements that prohibit training on your data. PHI is minimized before processing, not retained by the AI layer beyond the request, and encrypted in transit and at rest. Reviewer decisions calibrate prioritization; they never become training data. Full detail on the Security page.
Lines we don't cross

What Medically will not do.

Bill autonomously.Nothing reaches the claim or the record on the model's word alone. A person signs every change.
Assert without a citation.A finding that cannot be traced to verbatim chart text with a location is discarded, not displayed.
Only move revenue up.The same pass produces downgrades and unsupported-diagnosis findings, with equal prominence.
Hide the score's arithmetic.Every defensibility score stores its breakdown and scorer version. There is no black-box confidence number.
Train on your patients.PHI is never used to train AI models. Enterprise agreements prohibit it; minimization and transient processing enforce it.
Change models silently.Model and prompt versions are recorded on every finding. New behavior ships in shadow mode before it is shown.
Bring this to your evaluation

Nine questions to ask any AI revenue-integrity vendor.

Ask us the same ones. Here is how we answer.

Q1

Does it flag downgrades and unsupported diagnoses with the same prominence as upgrades?

Medically

Yes. One list, one ranking. Downside exposure is tracked in dollars alongside upside.

Q2

Can every finding be traced to verbatim chart text, with a location?

Medically

Yes. A finding without a located quote is discarded before anyone sees it.

Q3

Is there a clinical-validation risk score, and can you show its arithmetic?

Medically

Yes. A deterministic 0–100 defensibility score with its breakdown and scorer version stored on every finding.

Q4

Whose clinical criteria does it apply — one definition, or the payer's?

Medically

The payer's. A versioned criteria registry per payer, chosen by your hospital, recorded on every result.

Q5

What is logged when a reviewer accepts, rejects, or queries a finding?

Medically

Disposition, required reason code, reviewer, timestamp, evidence, criteria version, and model and prompt IDs — appended, never overwritten.

Q6

Can we export all of that for an auditor?

Medically

Yes. A permission-gated OIG-ready export. It contains verbatim chart text, so access to it is controlled and logged.

Q7

Do you publish precision and acceptance rates, and how do you monitor drift?

Medically

In your compliance console, by finding type. New finding types run in shadow mode first; drift and bias are monitored by payer and service line.

Q8

Is our PHI used to train your models?

Medically

No. Enterprise agreements prohibit it; PHI is minimized before processing and not retained by the AI layer beyond the request.

Q9

Can it code or bill without a human?

Medically

No. Nothing reaches the record or the claim without a credentialed person's sign-off, and that sign-off carries a reason code.

For compliance officers

Bring your hardest chart. We'll show you the ledger.

A 30-minute walkthrough built for compliance, HIM, and internal audit: two-way findings, the score breakdown, the reason-coded ledger, and the export — on a de-identified chart or your own.

Have questions first? Contact us →