Standard 28 — Digital Care and Artificial Intelligence Systems for Care
Criteria in this standard
28.2 — Digital Care Never Disadvantages a Patient Who Cannot Use It
28.3 — Genuine Technical Support Is Available for Digital Systems
28.4 — AI Systems Are Introduced in Line With Law and Best-Practice Guidance
28.5 — AI Systems Are Genuinely Monitored for Unintended Consequences
28.6 — Staff Are Genuinely Consulted Before an AI System Is Introduced
28.7 — Accountability for AI-Assisted Care Is Explicitly Defined
28.8 — Patients Are Genuinely Informed When Their Care Involves AI
Digital Systems Are Genuinely Evaluated Before Adoption
Standard
In plain terms: Before the clinic signs up for a new digital tool, someone has actually checked it’s worth it and will genuinely work with what the clinic already has — not adopted because a sales rep made it sound good.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
Ambulatory clinics are frequent targets for digital health vendors offering booking, portal, and clinical-support tools, often with compelling pitches and limited internal IT capacity to independently evaluate them. A clinic that adopts tools based on enthusiasm rather than genuine evaluation risks ending up with systems that don’t actually integrate with its patient records, create workflow friction rather than relief, or introduce risks nobody considered before go-live.
What good looks like
- A genuine cost/benefit evaluation happens before adoption.
- Compatibility with existing systems is genuinely checked.
- Potential unintended consequences are genuinely considered before go-live.
Common failure modes
- A system is adopted purely on a vendor demonstration with no independent check.
- Compatibility problems surface only after the system is already live.
- Unintended consequences are discovered only in hindsight.
Worked example
If you are starting from zero — do this first
- Build a simple one-page evaluation checklist for cost, benefit, and compatibility.
- Require it before any new digital system is adopted, even during a trial.
- Specifically ask what could go wrong before going live.
Self-assessment questions
Evidence: Evaluation checklist
Evidence: Compatibility check record
Evidence: Pre-launch risk review
Common reasons for a PARTIAL answer
- A free trial is treated as low-stakes and skips the evaluation entirely. — A trial that leads to continued use should still be evaluated before genuine adoption.
Implementation plan
| When | What |
|---|---|
| Week 1 | Build a simple evaluation checklist. |
| Ongoing | Apply it before any new digital system, including trials. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Evaluation review | Reviews the evaluation record for a recently adopted digital system. |
Supervisor tips
- Ask about the most recently adopted digital tool, trial or otherwise.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Digital Care Never Disadvantages a Patient Who Cannot Use It
Core
In plain terms: A patient who can’t use the online booking system or doesn’t have internet still gets exactly the same real access to the clinic — a working alternative, not a quietly worse option.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
Ambulatory clinics increasingly rely on digital booking and patient portals for efficiency, but the patients most likely to need outpatient care — older adults, those in lower-income circumstances, people with disabilities affecting digital use — are frequently the same patients least able to navigate a digital-only pathway. This is marked Core because the risk here is a real, direct equity failure: a clinic’s digital modernisation can quietly reduce access for exactly the patients who need it protected.
What good looks like
- A genuine, equally functional alternative exists for patients who cannot use digital channels.
- New digital services are genuinely pre-tested with affected patient representatives.
- Real evidence shows the alternative delivers equivalent, undiminished service.
Common failure modes
- Phone booking exists nominally but is deprioritised in practice, with long waits.
- A new digital service launches with no testing among patients who might struggle.
- The alternative is never actually tested to confirm it’s genuinely equivalent.
Worked example
If you are starting from zero — do this first
- Test your own non-digital booking channel directly, as a patient would.
- Assign clear staffing responsibility for the alternative channel.
- Track wait times to confirm genuine, ongoing parity.
Self-assessment questions
Evidence: Documented alternative channel
Evidence: Pre-launch testing record
Evidence: Direct test or comparison data
Common reasons for a PARTIAL answer
- The alternative exists but is genuinely slower or less reliable than the digital route.
Implementation plan
| When | What |
|---|---|
| Week 1 | Test the non-digital channel directly and measure wait time. |
| Week 2 | Assign clear staffing coverage for the alternative. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Direct test | Personally tests the non-digital alternative channel. |
Supervisor tips
- Call the clinic’s own phone line during business hours to test it directly.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Genuine Technical Support Is Available for Digital Systems
Standard
In plain terms: When a digital system breaks, there’s a real person to call for help — not a system left to run itself with nobody actually responsible for fixing it.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
Most ambulatory clinics lack dedicated in-house IT staff, which makes a genuine, accessible vendor support arrangement especially important — without it, a digital system failure can bring booking, records, or communication to a halt with no real path to resolution. A clinic doesn’t need its own IT department to meet this intent; it needs a real, known, accessible support relationship for every digital system it genuinely depends on.
What good looks like
- Genuine, accessible technical support exists for every digital system in use.
- Testing genuinely occurs before full implementation.
- A real, known escalation path exists for issues.
Common failure modes
- No clear support arrangement exists for a system in daily clinical use.
- Staff don’t know who to contact when something breaks.
Worked example
If you are starting from zero — do this first
- List every digital system in use and confirm a real support contact for each.
- Post support contacts visibly for staff who use each system.
Self-assessment questions
Evidence: Support contract or arrangement
Evidence: Pre-launch testing record
Evidence: Staff interview, posted contact
Common reasons for a PARTIAL answer
- Support knowledge depends on one staff member rather than a documented, shared record.
Implementation plan
| When | What |
|---|---|
| Week 1 | Document support contacts for every digital system in use. |
| Week 2 | Post contacts visibly for staff who use each system. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Staff interview | Asks a staff member who they’d contact for a digital system issue. |
Supervisor tips
- Ask a front-desk staff member, not just the clinic manager.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
AI Systems Are Introduced in Line With Law and Best-Practice Guidance
Standard
In plain terms: Before using an AI tool in patient care, the clinic has actually checked what the law requires, or grounded its approach in real published guidance if there’s no specific law — not made it up as it went along.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
Smaller clinics adopting AI-assisted tools — increasingly common in areas like diagnostic imaging triage or symptom-checking — are just as subject to the responsibilities of genuine governance as larger facilities, even without dedicated compliance staff. A real, citable basis for how the clinic governs its AI tools, even a simple one, is what separates responsible adoption from an unexamined decision with no actual grounding.
What good looks like
- AI systems are genuinely introduced in line with applicable law, where it exists.
- Where no law exists, introduction is genuinely informed by recognized guidance.
- The clinic can identify, when asked, the specific basis for AI governance.
Common failure modes
- No reference to law or guidance was made before adopting an AI tool.
- Nobody can say, when asked, what the governance basis actually is.
Worked example
If you are starting from zero — do this first
- Check for applicable AI-specific regulation in your jurisdiction.
- Where none exists, formally adopt a recognized guidance source as reference.
- Document this basis in a simple, one-page note.
Self-assessment questions
Evidence: Regulatory check record
Evidence: Documented guidance reference
Evidence: Staff interview
Common reasons for a PARTIAL answer
- A guidance source is named but hasn’t actually been reviewed for its application here.
Implementation plan
| When | What |
|---|---|
| Week 1 | Research applicable AI regulation. |
| Week 2 | Document a governance basis for each AI tool in use. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Governance note review | Reviews the documented governance basis for AI use. |
Supervisor tips
- Ask for the name of the specific guidance document, not a general assurance.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
AI Systems Are Genuinely Monitored for Unintended Consequences
Standard
In plain terms: The clinic actually keeps checking whether its AI tools are working as expected — not deploying a tool once and simply trusting it from then on.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
A clinic using an AI triage or diagnostic-support tool is depending on it to behave consistently well — but AI systems can fail in ways that aren’t visible in any single encounter, and only genuine, ongoing review of its actual output against independent clinical judgment will catch a systematic pattern of error.
What good looks like
- AI output is genuinely, periodically audited against independent review.
- Patient concerns related to AI-assisted care are genuinely tracked.
- A documented instance exists of monitoring catching a real issue.
Common failure modes
- AI output is trusted with no ongoing audit of its real accuracy.
- No monitoring process has ever actually caught an issue.
Worked example
If you are starting from zero — do this first
- Identify every AI tool currently influencing clinical decisions.
- Establish a simple, periodic audit comparing output against independent review.
Self-assessment questions
Evidence: Audit record
Evidence: Tracking log
Evidence: Issue response record
Common reasons for a PARTIAL answer
- Auditing happens but isn’t genuinely independent of the AI vendor itself.
Implementation plan
| When | What |
|---|---|
| Week 1-2 | Establish a periodic, independent audit process. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Audit review | Reviews the periodic AI audit record for genuine, independent comparison. |
Supervisor tips
- Ask whether the audit has ever actually found anything worth flagging.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Staff Are Genuinely Consulted Before an AI System Is Introduced
Standard
In plain terms: Before a new AI tool goes live, the staff who will actually use it have had a real say — not just been told it’s coming.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
In a small clinical team, staff experience is especially valuable because there’s no large IT department standing between the decision and the people actually using the tool day to day — their early, genuine input often catches practical friction that a vendor’s generic rollout plan misses entirely.
What good looks like
- Staff are genuinely consulted before, not after, an AI system’s introduction.
- Consultation genuinely identifies training needs, actually delivered.
- Staff asked directly can describe genuine consultation.
Common failure modes
- Staff learn about a new tool only once the decision is already final.
Worked example
If you are starting from zero — do this first
- Hold a consultation session before finalizing any AI system decision.
Self-assessment questions
Evidence: Consultation record
Evidence: Training delivery record
Evidence: Staff interview
Common reasons for a PARTIAL answer
- Consultation happened with one lead clinician but not the wider team.
Implementation plan
| When | What |
|---|---|
| Before any launch | Hold genuine consultation with actual users. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Staff interview | Asks frontline staff whether they felt genuinely consulted. |
Supervisor tips
- Ask for a specific example of something changed because of staff input.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Accountability for AI-Assisted Care Is Explicitly Defined
Core
In plain terms: Everyone knows, in advance, who is actually responsible if an AI-supported decision turns out to be wrong — not a question nobody has thought through.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
This is marked Core for the same reason it is at any facility scale: without explicit accountability, a safety incident involving AI-assisted care risks becoming a confused dispute over responsibility exactly when clarity matters most — for the patient, the clinician, and the clinic’s own ability to learn from what happened.
What good looks like
- Clinical accountability for AI-supported decisions is explicitly documented.
- Clinicians genuinely understand their own accountability.
- A defined process exists for reviewing accountability in an incident.
Common failure modes
- Accountability has never been explicitly addressed.
Worked example
If you are starting from zero — do this first
- Explicitly document where clinical accountability sits for each AI-supported decision.
Self-assessment questions
Evidence: Documented accountability policy
Evidence: Staff interview
Evidence: Incident review protocol
Common reasons for a PARTIAL answer
- A policy exists but hasn’t been communicated to frontline staff.
Implementation plan
| When | What |
|---|---|
| Week 1 | Document explicit accountability for each AI tool in use. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Staff interview | Asks a clinician to describe their accountability when using an AI-supported tool. |
Supervisor tips
- Ask a clinician directly: if the AI flagged something wrong, who is responsible?
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Patients Are Genuinely Informed When Their Care Involves AI
Standard
In plain terms: If AI is actually involved in part of a patient’s care, they’re genuinely told — not left to assume a human made every decision alone.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Adapted | Full | Full | Full |
Why this matters
A patient’s genuine right to understand their own care includes knowing, in plain terms, when a decision affecting them was shaped by an AI system rather than a clinician’s judgement alone. This isn’t a formality — a patient who genuinely knows AI was involved can ask informed questions, seek a second opinion with that context, or simply understand their care more completely. Disclosure buried in a general consent form a patient never actually reads does not meet this bar.
What good looks like
- Patients are genuinely informed when AI is involved in their care.
- Disclosure is genuinely understandable, in plain language.
- A patient can genuinely confirm they were told.
Common failure modes
- AI disclosure is buried in a general consent form, technically present but never genuinely read or understood.
Worked example
If you are starting from zero — do this first
- Add a brief, plain-language disclosure point at the moment care decisions involving AI are actually discussed with the patient.
Self-assessment questions
Evidence: Disclosure protocol
Evidence: Disclosure wording sample
Evidence: Patient interview
Common reasons for a PARTIAL answer
- Disclosure exists in a consent form but patients genuinely cannot recall or explain it when asked directly.
Implementation plan
| When | What |
|---|---|
| Week 1-2 | Draft plain-language disclosure wording for each AI-assisted care point and train staff to deliver it. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Patient interview | Asks a patient whether they were genuinely told AI was involved in their care. |
Supervisor tips
- Ask a patient directly rather than relying on the consent form’s existence alone.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.