The robots aren’t taking over – the humans are

Claims

By Matthew Sellers

Nov 28, 2025Share

Florida lawmakers aim to restrict automated claims decisions, with a bill requiring human professionals to make all claim denials.

House Bill 527, sponsored by Rep. Hillary Cassel and filed on November 24, 2025, would require that every claim denial in the state be made by a qualified human professional, not a computer system acting alone. The legislation is proposed to take effect on July 1, 2026.

The bill imposes a clear requirement: automated tools can assist in the claims process, but they cannot be the sole basis for denying a claim.

For insurance professionals operating in Florida, one of the nation's largest insurance markets, the implications are significant. The bill would require carriers to maintain human involvement in their claims operations whenever a denial decision is made.

The legislation establishes specific definitions for the tools it restricts. An algorithm is a mathematical process designed to produce specific results. An artificial intelligence system is a machine-based tool that can generate outputs like predictions or recommendations that influence decisions. A machine learning system is an AI tool that learns from data without being explicitly programmed. Under the bill, none of these could serve as the sole reason for denying a claim.

Before making any decision to deny a claim or part of a claim, a qualified human professional must first analyze the facts and policy terms independently of any automated system. They must then review whatever the algorithm or AI tool produced to check for accuracy. If another person already reviewed the claim, that human professional must conduct their own review as well.

This requirement means companies cannot rely on an algorithm to filter claims and then have a human approve the decision without independent analysis. The human reviewer must conduct substantive work.

Insurers will also face new documentation obligations. Companies must maintain detailed records showing who made each denial decision and who reviewed it, along with the date and time. They must document the basis for every denial, including any information provided by automated systems, creating an audit trail that regulators can examine.

When notifying a claimant about a denial, the company must clearly identify the qualified human professional who made the decision. The insurer must also explicitly state that an algorithm or AI system did not serve as the sole basis for the denial.

For insurers that use automated systems in their claims process, the bill requires them to explain in their claims-handling manuals how those tools work and how the company ensures compliance with the new requirements.

The Office of Insurance Regulation will have authority to examine carriers and investigate compliance with the rules. The Financial Services Commission can adopt additional rules to implement the statute.

From a practical standpoint, carriers that have automated significant portions of their claims operations will need to adjust their workflows to ensure that human professionals conduct independent analysis before any claim denial is finalized.

The bill has not yet been enacted, but its introduction indicates that the conversation about automation in insurance claims is shifting from operational efficiency to accountability and human oversight.

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