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Committee hears proposal to require disclosure when AI alters health billing codes

Joint Interim Committee on Information Management and Technology · November 18, 2025
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Summary

Committee members discussed drafting a concept to require insurers to disclose if automated systems (AI) altered provider-submitted billing codes, after members reported instances of claims being "downcoded" without provider notice and raised concerns about appealability and transparency.

Representative Aaron Nathanson and committee staff described reports from health care providers that insurers may be using automated tools to alter submitted billing codes — a practice described in the meeting as "downcoding" — without notifying the provider. "I wrote this, but it was changed into something else… The claim was just changed, changed by not a human, changed by an AI program," Nathanson said, arguing the committee should consider drafting a disclosure requirement and an appeals process.

Committee members asked whether Oregon already has disclosure requirements tied to AI use; staff said some sector-specific disclosures exist (for example, rules about using titles like "nurse" in synthetic media and previous disclosure measures in elections and campaigning) but no comprehensive statewide requirement covering insurer use in claims processing was cited.

Staff said a potential committee concept would focus on disclosure that AI was used to alter or process claims, transparency about how automated decisions were made, and clarity about consumer or provider recourse and appeals. Members discussed how disclosure requirements could strike a balance between preserving innovation and ensuring providers and consumers can understand and contest automated alterations.

Committee chairs said they will request drafting assistance to create a concept for committee review; the draft would be vetted with affected stakeholders before being considered for introduction in a future session.