Standard Operating Procedure for Vision-Based AI Form Filling in Prior Authorizations
2026-01-20
1.0
Draft
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.
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.
Specify departments, systems, and workflows covered by this SOP.
3. Audience
The primary audience responsible for following this SOP includes:
Clinical Staff
Compliance Personnel
4. Definitions
Term
Definition
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
Regulation / Standard
Description
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
Role
Responsibility
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
7.1 System Access and Security
Ensure user access is role-based and authorized
Maintain audit trails in compliance with 21 CFR Part 11
Verify electronic signatures where applicable
7.2 Input Document Handling
Confirm source documents are complete and legible
Validate document version and payer requirements
Upload documents according to defined workflow
7.3 AI Form Filling Process
Initiate vision-based AI processing
Monitor AI extraction and field population
Flag low-confidence fields for manual review
7.4 Human Review and Verification
Clinical Staff must review all AI-populated data
Correct errors identified during review
Document verification completion
7.5 Submission and Record Retention
Submit completed prior authorization forms per payer guidelines
Archive records in validated electronic systems
Retain records according to organizational retention policy
8. Validation and Change Management
Validate AI systems prior to production use
Document model updates, retraining, and configuration changes
Perform revalidation following significant changes
Describe validation protocol references and change control procedures.
9. Risk Management
Identify risks related to incorrect data extraction
Implement mitigation controls and monitoring
Review incidents and corrective actions
10. Training Requirements
All users must complete initial and periodic training
Training records must be maintained
Competency assessments should be documented
11. Monitoring, Auditing, and Continuous Improvement
Conduct periodic audits of AI performance and compliance
Track key performance indicators and error rates
Implement corrective and preventive actions as needed