Ohio: AI health laws

ODM AI Policy Guidance for Managed Care Entities (MCEs), Ohio Department of Medicaid

Bars Medicaid managed care entities from deploying AI that determines a service denial, limitation or termination independent of a human final decisionmaker, and requires human oversight of all AI, department approval before moderate- or high-risk uses such as prior authorization automation, conspicuous website notice to members when AI affects their health decisions or they interact with AI, governance policies and staff training, an inventory of existing AI tools by Sept. 30, 2026, and quarterly inventories after that.

Physician read. It places no duty on physicians. Since April 2026, an Ohio Medicaid managed care plan may not let an AI tool deny, limit or terminate a service without a human final decisionmaker, though the guidance does not say that person must be a clinician, and it needs the department's approval before automating prior authorization.

Applies to: Ohio Medicaid managed care entities: Ohio Managed Care, MyCare Ohio and OhioRISE plans and the single pharmacy benefit manager
Also touches: Patient disclosure of AI use

Notes: Issued April 24, 2026; the memo states no separate effective date, so the issue date is used. Existing AI tools may stay in use but had to be listed in an inventory due Sept. 30, 2026, with quarterly inventories starting in the first quarter of state fiscal year 2027; the approval requirement applies to planned or future moderate- and high-risk uses. The memo ties its requirements to the Ohio Medicaid managed care, MyCare Ohio and OhioRISE provider agreements (Appendix K). Its appendix rates prior authorization automation and automated eligibility determination as high risk, and claims triage and generative AI for member communications as moderate to high. It also bars AI that incorporates biometrics without the department's approval and the training of public generative AI models on member data. It does not address notices to providers.