AI Legion Health - commerce.utah.gov

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Legion Health AI

Legion Health AI Mitigation Agreement

Smarter Psychiatry. Faster Refills. Safer Care.

Legion Health is an AI-enabled psychiatry clinic that combines licensed clinicians with advanced technology to improve access to care. Their focus is on safe AI routine prescription refills so that patients can get care faster and clinicians can focus on where they are needed most.

The Approach

Legion’s approach is intentionally narrow. The system only supports refills for stable patients on existing, non-controlled medications, like common treatments for anxiety and depression. It does not diagnose, prescribe new medications, or adjust doses.

What Patients Experience

Patients can request a refill in minutes. They are clearly informed that AI is part of the process, they verify their identity and prescription and answer a few targeted questions about how they are doing. If everything checks out, the refill is sent to their pharmacy. If not, they are quickly connected to a clinician.

Why It Matters

• Access Gap: Many parts of Utah don’t have enough mental health providers, making it difficult for people to get care.

• Reducing Bottlenecks: Prescription refills can be slow and time-consuming. Making this process faster helps patients get their medication without delays and stay on track.

• Expanding Clinical Capacity: By handling routine tasks, AI gives providers more time to focus on patients who need more complex care.

Why It Matters

Defined Scope and Accountability This pilot runs for 12 months with special approval. While certain rules are relaxed for this project, all standard patient protections and legal responsibilities still apply.

Strict BoundariesThe AI is limited to renewing existing, non-controlled prescriptions. It cannot initiate new treatments, adjust dosages, or prescribe higher-risk medications.

Built-In EscalationConservative safety checks ensure that any risk—such as suicidality, severe side effects, signs of mania, or pregnancy—triggers immediate review by a licensed clinician. Patients may also request human review at any time.

Phased ValidationThe system is introduced gradually to ensure safety at every step:

• First 250 requests: reviewed by a licensed clinician before completion

• Next 1,000 requests: undergo intensive retrospective review to confirm accuracy

• Ongoing: monthly randomized sampling and auditing of cases

• Detailed Monthly reporting to OAIP

Feedback

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Prescription Renewals FAQs

How do AI prescriptions work in these pilots?

For the entirety of these pilots, these AI tools are only permitted to renew existing prescriptions ordered by a licensed physician. New prescriptions or changes in dose or frequency must be ordered by a licensed physician.

During the first phase, a licensed physician must review the prescription renewal recommended by the AI tool before it is sent to a pharmacist. If companies meet agreed upon benchmarks and perform well in the first phase, they will move on to the second phase.

During the second phase, the AI tool may submit the prescription renewal directly to the pharmacist. Pharmacists will retain authority to escalate any AI-generated renewals to a licensed physician within the prescribing company and pharmacists will be provided a method to directly communicate escalations with each company.

Prescription renewal pilots authorized by our office are designed to minimize impacts on pharmacist workflow.

What medications can be prescribed?

OAIP has worked with regulators, pharmacists, clinicians, and regulatory mitigation recipients to come up with a unique formulary for each company pilot, ranging from a list of about 20 to about 200 approved medications. These formularies are designed to address common medications used for chronic conditions and mental health management, and do not include any controlled substances.

Formularies for each pilot can be found within the signed agreement.

If it’s generated by AI, then whose name is on the prescription?

All prescription refills are signed and approved by a licensed physician, either directly or vicariously through the AI system’s protocol. Thus, orders are still being issued by a licensed practitioner.

What if a pharmacist needs additional information, clinical clarification, or documentation?

Our regulatory mitigation recipients are required to provide a direct line for pharmacists to communicate escalations with licensed professionals employed by the prescribing company.

During these pilots, an AI tool will never prescribe new medications. Patients must go through identity and prescription verification processes in order to qualify for AI-generated prescription renewals. Through that process, the AI-enabled prescription service will have information about the original prescribing physician and can relay necessary information to a pharmacist upon request. Additionally, there is always a physician’s name attached to a prescription authorization.

What mechanisms exist to ensure alignment between provider intent and the system-generated prescriptions?

There are several relevant safeguards in place in these agreements. Controlled substances are specifically excluded from the renewal process, focusing on medications with established safety profiles for routine renewal.

Additionally, patients participating in the program will only be permitted a limited number refills per prescribed medication without a subsequent in person or telehealth visit with a clinician licensed to practice medicine in the State of Utah.

Finally, The AI system includes built-in escalation protocols that automatically refer cases to human physicians when clinical complexity exceeds predetermined safety thresholds, when conflicting information is detected, or when the patient's clinical status suggests potential medication-related complications.

What oversight can the public expect?

OAIP receives monthly reports from regulatory mitigation recipients to monitor their work. The details of metrics to be shared in these reports are detailed in their contracts (agreements can be found on the OAIP website). OAIP carefully vets and confirms key metrics, the most important being safety.

If an AI tool approves a refill and an adverse event occurs, how is liability determined?

Our office structures these pilots in a way that makes the risk of adverse events like this low, yet we recognize the possibility of such an event. Recipients of regulatory mitigation employ a licensed physician whose name appears on AI-generated prescription renewals. As a part of our agreement, we expect companies in the regulatory mitigation program to maintain medical malpractice insurance that covers AI liabilities and risk.

Is this program permanent?

These pilots are a part of the Office of AI Policy’s statutory authority to authorize AI use cases requiring regulatory relief for a limited time.

For example, the Doctronic pilot will run for 1 year (Oct 2025 - Oct 2026) with the option for the office to review and renew the contract for another year.

Does this mean any AI can practice medicine in Utah?

No. Agreements are temporary and conditional on adherence to the agreement.