Update SOPs/SOP-IT-001-Vision-Based-AI-Form-Filling-for-Prior-Authorizations.md

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## 1. Purpose ## 1. Purpose
This Standard Operating Procedure (SOP) defines the standardized process for using vision-based artificial intelligence (AI) systems to perform form filling for prior authorization submissions. The purpose is to ensure accuracy, data integrity, regulatory compliance, and consistent operational performance in accordance with FDA 21 CFR Part 11, ISO 9001, and ISO 13485 requirements. This Standard Operating Procedure (SOP) defines the standardized process for using vision-based artificial intelligence (AI) systems to perform form filling for prior authorization submissions. The purpose is to ensure accuracy, data integrity, regulatory compliance, and consistent operational performance in accordance with FDA 21 CFR Part 11, ISO 9001, and ISO 13485 requirements.
## 2. Scope ## 2. Scope
This SOP applies to all activities related to the use, validation, operation, monitoring, and maintenance of vision-based AI technologies used to extract, interpret, and populate prior authorization forms. This SOP applies to all activities related to the use, validation, operation, monitoring, and maintenance of vision-based AI technologies used to extract, interpret, and populate prior authorization forms.
*Specify departments, systems, and workflows covered by this SOP.* *Specify departments, systems, and workflows covered by this SOP.*
## 3. Audience ## 3. Audience
The primary audience responsible for following this SOP includes: The primary audience responsible for following this SOP includes:
- Clinical Staff - Clinical Staff
- Compliance Personnel - Compliance Personnel
## 4. Definitions ## 4. Definitions
| Term | Definition |
|-----|------------| TermDefinitionVision-Based AIArtificial intelligence systems that use optical character recognition and computer vision to interpret visual dataPrior AuthorizationA requirement from a payer for approval before specific healthcare services are providedData IntegrityAssurance that data is accurate, complete, and maintained throughout its lifecycle
| Vision-Based AI | Artificial intelligence systems that use optical character recognition and computer vision to interpret visual data |
| Prior Authorization | A requirement from a payer for approval before specific healthcare services are provided |
| Data Integrity | Assurance that data is accurate, complete, and maintained throughout its lifecycle |
## 5. Regulatory and Quality References ## 5. Regulatory and Quality References
| Regulation / Standard | Description |
|-----------------------|-------------| Regulation / StandardDescriptionFDA 21 CFR Part 11Electronic Records and Electronic SignaturesISO 9001Quality Management Systems RequirementsISO 13485Medical Devices Quality Management SystemsHIPAAHealth Insurance Portability and Accountability Act
| FDA 21 CFR Part 11 | Electronic Records and Electronic Signatures |
| ISO 9001 | Quality Management Systems Requirements |
| ISO 13485 | Medical Devices Quality Management Systems |
| HIPAA | Health Insurance Portability and Accountability Act |
## 6. Roles and Responsibilities ## 6. Roles and Responsibilities
| Role | Responsibility |
|------|----------------| RoleResponsibilityClinical StaffReview AI-populated forms for clinical accuracyComplianceEnsure adherence to regulatory and quality requirementsIT / AI System OwnerMaintain system availability, security, and performanceQuality AssuranceOversight of validation, audits, and continuous improvement
| Clinical Staff | Review AI-populated forms for clinical accuracy |
| Compliance | Ensure adherence to regulatory and quality requirements |
| IT / AI System Owner | Maintain system availability, security, and performance |
| Quality Assurance | Oversight of validation, audits, and continuous improvement |
## 7. Procedure ## 7. Procedure
### 7.1 System Access and Security ### 7.1 System Access and Security
- Ensure user access is role-based and authorized - Ensure user access is role-based and authorized
- Maintain audit trails in compliance with 21 CFR Part 11 - Maintain audit trails in compliance with 21 CFR Part 11
- Verify electronic signatures where applicable - Verify electronic signatures where applicable
### 7.2 Input Document Handling ### 7.2 Input Document Handling
- Confirm source documents are complete and legible - Confirm source documents are complete and legible
- Validate document version and payer requirements - Validate document version and payer requirements
- Upload documents according to defined workflow - Upload documents according to defined workflow
### 7.3 AI Form Filling Process ### 7.3 AI Form Filling Process
- Initiate vision-based AI processing - Initiate vision-based AI processing
- Monitor AI extraction and field population - Monitor AI extraction and field population
- Flag low-confidence fields for manual review - Flag low-confidence fields for manual review
### 7.4 Human Review and Verification ### 7.4 Human Review and Verification
- Clinical Staff must review all AI-populated data - Clinical Staff must review all AI-populated data
- Correct errors identified during review - Correct errors identified during review
- Document verification completion - Document verification completion
### 7.5 Submission and Record Retention ### 7.5 Submission and Record Retention
- Submit completed prior authorization forms per payer guidelines - Submit completed prior authorization forms per payer guidelines
- Archive records in validated electronic systems - Archive records in validated electronic systems
- Retain records according to organizational retention policy - Retain records according to organizational retention policy
## 8. Validation and Change Management ## 8. Validation and Change Management
- Validate AI systems prior to production use - Validate AI systems prior to production use
- Document model updates, retraining, and configuration changes - Document model updates, retraining, and configuration changes
- Perform revalidation following significant changes - Perform revalidation following significant changes
@@ -76,39 +75,37 @@ The primary audience responsible for following this SOP includes:
*Describe validation protocol references and change control procedures.* *Describe validation protocol references and change control procedures.*
## 9. Risk Management ## 9. Risk Management
- Identify risks related to incorrect data extraction - Identify risks related to incorrect data extraction
- Implement mitigation controls and monitoring - Implement mitigation controls and monitoring
- Review incidents and corrective actions - Review incidents and corrective actions
## 10. Training Requirements ## 10. Training Requirements
- All users must complete initial and periodic training - All users must complete initial and periodic training
- Training records must be maintained - Training records must be maintained
- Competency assessments should be documented - Competency assessments should be documented
## 11. Monitoring, Auditing, and Continuous Improvement ## 11. Monitoring, Auditing, and Continuous Improvement
- Conduct periodic audits of AI performance and compliance - Conduct periodic audits of AI performance and compliance
- Track key performance indicators and error rates - Track key performance indicators and error rates
- Implement corrective and preventive actions as needed - Implement corrective and preventive actions as needed
## 12. Documentation and Records ## 12. Documentation and Records
| Record Type | Storage Location | Retention Period |
|------------|------------------|------------------| Record TypeStorage LocationRetention PeriodAI Output Logs""""Audit Trails""""Training Records""""
| AI Output Logs | "" | "" |
| Audit Trails | "" | "" |
| Training Records | "" | "" |
## 13. Deviations ## 13. Deviations
- Document any deviations from this SOP - Document any deviations from this SOP
- Assess impact and implement corrective actions - Assess impact and implement corrective actions
- Obtain approval for deviation closure - Obtain approval for deviation closure
## 14. Version Control ## 14. Version Control
| Version | Date | Description of Change | Author |
|--------|------|----------------------|--------| VersionDateDescription of ChangeAuthor1.02026-01-20Initial draft""
| 1.0 | 2026-01-20 | Initial draft | "" |
## 15. Approval Signatures ## 15. Approval Signatures
| Name | Title | Signature | Date |
|------|-------|-----------|------| NameTitleSignatureDate""""""""""""""""
| "" | "" | "" | "" |
| "" | "" | "" | "" |