Utah approves AI healthcare pilots allowing prescriptions without direct doctor oversight

Utah's Office of Artificial Intelligence Policy has approved a groundbreaking pilot program with startup Nolla Health, allowing its Nolla Derm app to diagnose mild-to-moderate acne and issue prescriptions without direct doctor oversight. Operating under the state's 2024 AI sandbox law, the program will transition from human-in-the-loop validation to fully automated prescribing. While Nolla Health CEO Luis Wenus highlights increased affordability and accessibility, the medical community, including the American Medical Association and the Utah Medical Licensing Board, has expressed strong opposition over patient safety and legal liability.

Approval of new healthcare AI pilots

• ▪The newly approved pilot with Expect Fitness will offer virtual pelvic floor therapy for women in Utah to address urinary incontinence, pelvic pain, and postpartum pelvic floor problems.
• ▪The Utah Office of Artificial Intelligence Policy approved three new healthcare AI pilots on October 2, 2026, covering acne prescription, chronic condition drug renewals, and virtual pelvic floor therapy.
• ▪The newly approved pilot with August AI will test an artificial intelligence system designed to renew prescriptions for patients with chronic conditions.

Implementation of the Nolla Health pilot

• ▪Utah's Office of Artificial Intelligence Policy approved a plan on October 5, 2026, allowing an artificial intelligence product to evaluate patients and write new drug prescriptions without direct human oversight.
• ▪The Nolla Health pilot will operate in three stages, starting with 100 prescriptions reviewed by physicians before submission, followed by 400 prescriptions submitted by AI and reviewed retrospectively.
• ▪In the final stage of the Nolla Health pilot, prescriptions are fully automated by the AI, with a physician retrospectively reviewing at least 10% of the total monthly prescriptions.
• ▪The startup Nolla Health launched a one-year pilot program in Utah on October 5, 2026, using its Nolla Derm app to analyze photos and medical histories of adults with mild-to-moderate acne.

Features and safety of the Nolla Derm app

• ▪Nolla Health Chief Executive Luis Wenus stated that the app's topical treatments carry low risks of adverse reactions, limited to localized skin irritation or dryness.
• ▪The Nolla Derm app generates a numerical acne severity score and recommends topical treatments from a list of eight physician-approved medications, costing patients $4.99 per month.

Involvement of the Utah Medical Licensing Board

• ▪The Utah Medical Licensing Board previously issued an open letter opposing an earlier pilot by Doctronic, stating they were not consulted and that the program placed citizens at risk.
• ▪The Nolla Health pilot was amended to include a third-party physician appointed by the Utah Medical Licensing Board to oversee prescription reviews.

Legal liability and contract requirements for AI pilots

• ▪Stanford University professor Michelle Mello argued in a JAMA Health Forum commentary that Doctronic's contract is legally murky regarding liability for potential AI-based prescribing errors.
• ▪To address legal ambiguities, the Office of Artificial Intelligence Policy requires a special malpractice insurance covering AI-generated prescriptions and builds specific duty of care provisions into contracts.

Regulatory framework for Utah's AI pilots

• ▪The Office of Artificial Intelligence Policy signed master agreements in September 2026 with University of Utah Health and Intermountain Health to set terms for potential future AI pilots.
• ▪Utah's Artificial Intelligence Learning Laboratory, or AI sandbox, was established by state law in 2024 to allow the Office of Artificial Intelligence Policy to waive regulations for testing AI products.

Debatable claims

• ▪Expanding healthcare access justifies the risks of Utah's autonomous AI pilots
• ▪Autonomous AI prescription renewals pose an unacceptable risk to patients with chronic conditions
• ▪Utah's regulatory sandbox is an appropriate way to foster healthcare innovation
• ▪Nolla Health's AI app is safe enough to prescribe acne medication without human oversight