According to ProPublica, Cigna doctors signed off claim denials in an average of 1.2 seconds each.
Every one had a human in the loop. But nobody had decided what a real review involved.
Most organisations using AI on decisions about people are in the same place. A person signs off, so the decision feels safe. The law now asks whether that review was real.
When AI is used for decisions with real consequences, it rarely fails because the technology is wrong. It fails because nobody decided, before launch, which decisions AI can handle alone and which need human judgement. That line is the boundary, and you need one however you run your AI:
- A person signs off every decision. At volume, this slides into the rubber-stamp trap. The boundary sets what a real review involves.
- A deliberate split. The boundary sets which decisions AI handles and which go to a person, and why.
- AI decides alone. The boundary sets when AI can act on its own. Where it can’t, the decision goes to a person.
Without a boundary set in advance, the AI draws its own. And when it is in the wrong place, the first to know is the employee, the regulator or the court.
Where this matters now
The regulator and the court aren’t hypothetical. The rules now set out when software can decide about people on its own, and when a person has to properly review the decision. Some of it already applies. More starts soon:
- 1 January 2027, California. California’s automated decision-making rules cover automated hiring, promotion, termination and other significant decisions, unless a person actually reviews them: someone who understands what the system produced and has the authority to change it.
- 1 July 2027, California (SB 947). Employers can’t rely solely on software to discipline or fire someone. A person must corroborate the output, and the employee must be told in writing.
- Now, everywhere in the US. If your company funds its own health plan, you’re responsible under federal law for how your administrator decides employees’ claims, including any use of software or AI.
These laws either require a real person or set conditions for letting AI decide alone. They don’t say which decisions need which, how long a real review takes, or what record will hold up if it’s challenged. Once a regulator or a lawyer asks, it’s too late to write it down.
That’s the work I do. I help you set the boundary before launch: what AI can decide alone, who holds authority where it can’t, and the record that proves it. Then I stay to put it in place.












