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AI, Regulation

Adoption of NAIC Model Bulletin

Tracking adoption of the NAIC's Model Bulletin on AI Use.

Elaine Gibbs, May 21, 2024

Twelve states and districts have adopted the NAIC Model Bulletin on the use of AI by insurers, in part or in whole, as of: May 21, 2024.

In order of adoption:

  • Alaska, February 1, 2024, Bulletin B 24-01: No notable changes

  • New Hampshire, February 20, 2024, Docket #INS 24-011-AB:

    • Strongly encourages development of verification and testing methods to identify errors and limit unfair discrimination (as opposed to simply encourages)

    • Updates “bias analysis and minimization” in reference to data management practices to “unfair bias analysis and minimization”

  • Nevada, February 23, 2024, Bulletin 24-001: No notable changes

  • Connecticut, February 26, 2024, Bulletin MC-25

    • Insurers must complete annual Artificial Intelligence Certification that attests to compliance with the Bulletin

  • Vermont, March 12, 2024, Insurance Bulletin 229: No notable changes

  • Illinois, March 13, 2024, Company Bulletin 2024-08: No notable changes

  • Rhode Island, March 15, 2024, Insurance Bulletin 2024-03: No notable changes

  • Pennsylvania, April 6, 2024, Notice 2024-04: No notable changes

  • Kentucky, April 16, 2024, Bulletin 2024-02

    • Clarifies that the guidelines in the bulletin are non-binding and softens the overall tone, using phrases like “the Department recommends,” “the Department advises,” or “controls would ideally address” 

  • Maryland, April 22, 2024, Bulletin 24-11:

    • Extends scope from insurers to include nonprofit health service plans, HMOs, and dental plan organizations

  • Washington, April 22, 2024, Technical Assistance Advisory 2024-02: No notable changes

  • District of Columbia, May 21, 2024, Bulletin 24-IB-002-05/21: No notable changes

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