Secure your platforms and products to drive insights from AI and accelerate healthcare transformation.
Artificial intelligence (AI) is transforming healthcare insurance. From streamlining underwriting to refining pricing models, data-driven decision-making is integral to competitiveness. But as these systems become more powerful, regulators, policymakers, and the public are demanding something just as important as accuracy: fairness.
For life and health insurance providers, this shift represents both a challenge and an opportunity. The challenge lies in proving that AI-driven models don’t create or perpetuate unfair discrimination. The opportunity lies in establishing governance practices that meet regulatory requirements and strengthen trust with consumers, regulators, and any interested parties.
Healthcare insurance providers operate in a heavily regulated sector. In the United States, state-level rules such as New York's Department of Financial Services Insurance Circular Letter No. 7¹ and Colorado's AI regulations for insurers² require companies to demonstrate that AI-driven underwriting and pricing decisions don’t disproportionately disadvantage protected classes or similarly situated insureds. Globally, emerging regulations are setting similar expectations for transparency, explainability, and fairness.
Similarly, the EU AI Act is setting a higher-water mark globally, classifying many AI systems used for insurance underwriting as a “high-risk” use case subject to strict transparency, human oversight, and fairness requirements.6 OECD AI Principles and regulatory developments in APAC markets, including Singapore and Australia, are also converging on the expectation that insurers can demonstrate robust governance across jurisdictions.8.9 For multinational providers, the challenge is harmonizing local compliance while maintaining consistent enterprise-wide standards.
The scrutiny is intensifying. Regulators increasingly want to see evidence that insurers have assessed how external data sources might create unintended disparities, measured outcomes to ensure consistent treatment of people with similar risk profiles, and implemented governance frameworks that can detect, mitigate, and prevent bias over time.
For consumers, bias is not an abstract concept, it can mean being denied affordable coverage, facing higher premiums, or experiencing delays in claims approval. Transparent governance gives individuals confidence that models are not treating them unfairly based on factors outside their control, such as zip or postal code, socioeconomic background, or prescription history. By centering governance on consumer impact, insurers can turn fairness into a differentiator rather than a defensive posture.
The risk of inaction is clear: models that unintentionally produce disparate impacts could lead to regulatory penalties, reputational harm, and loss of consumer trust. For example, consider where a U.S. insurer piloting a prescription-based risk score found that its model consistently overestimated risk for communities with limited access to pharmacies.4 By re-balancing the training data and adjusting feature weights, the insurer reduced disparate impacts while maintaining predictive accuracy.
Several factors make bias and governance an urgent priority for healthcare insurers:
A new layer of complexity comes from the use of generative AI and foundation models in insurance operations, such as automating claims documentation or supporting customer service chatbots. These systems introduce fresh risks, hallucinated outputs, opaque reasoning chains, and propagation of systemic biases across multiple downstream models. Insurers need to expand governance frameworks to cover these emerging technologies, ensuring oversight does not stop with traditional predictive models.
Best-practice governance for model bias is a structured, proactive approach that ensures decisions are accurate and equitable. In healthcare insurance, this involves several key components.
Understanding the regulatory landscape: Insurers should map their AI use cases against applicable laws at the state, national, and potentially even international levels. This includes identifying protected classes, understanding definitions of unfair discrimination , and staying current with evolving guidance.
Defining fairness in context: Fairness is not one-size-fits-all. In insurance, definitions may differ between regulators, and between group-level and individual-level assessments. Organizations will want to decide which fairness metrics (e.g., demographic parity, equalized odds) are appropriate for their underwriting and pricing models, and document their rationale.
Mapping models for bias risk: Every model, from a mortality risk score to a prescription-based pricing factor, should be mapped for potential bias entry points. This means analyzing input data, feature engineering steps, model outputs, and downstream decision rules to identify where disparities could emerge.
Measuring and monitoring fairness: Bias detection involves robust statistical evaluation across three key areas: comparing predicted outcomes across demographic groups, using statistical significance tests to assess differences, and tracking changes over time to catch emerging disparities as data shifts. Monitoring should be continuous, not a one-time exercise. Feedback loops ensure that if models begin to drift toward biased outcomes, corrective action can be taken quickly.
Mitigating bias and documenting actions: When disparities are detected, mitigation strategies could involve adjusting training datasets to improve representativeness, modifying features or decision thresholds, or introducing post-processing adjustments to outputs.
Documentation is also essential. Regulators expect demonstrable proof with records showing what was tested, what was found, and what actions were taken.
The end goal is creating a governance framework that is resilient to regulatory change, adaptable to new data sources, and capable of maintaining trust over the long term. In practice, that means embedding bias management into the entire AI lifecycle, from model design and development to deployment, monitoring, and retirement. Governance should be integrated with model risk management, underwriting policies, and operational workflows.
A defensible AI governance framework for healthcare insurance typically includes clear accountability, transparent methodologies, regulatory readiness, and global-local adaptability.
Healthcare insurance providers want to innovate to remain competitive, while safeguarding against the risks that advanced analytics can introduce. Fairness in AI is a matter of business sustainability.
Done well, robust model bias governance can strengthen trust by demonstrating that fairness is embedded in decision-making, reduce the likelihood of costly disputes, regulatory interventions, or reputational crises, enable more confident adoption of new data sources and AI techniques by ensuring risks are understood and managed from the outset, and create a competitive advantage in markets where regulators, partners, and customers increasingly demand transparency.
As AI continues to reshape healthcare insurance, bias management and governance become core capabilities. A successful approach involves structured, proactive, and transparent practices: mapping risks, selecting meaningful fairness metrics, embedding bias testing into regular workflows, and continuously improving governance frameworks.
The industry has reached a point where fairness in AI is a defining factor in long-term viability. In the coming years, leaders will build the most sophisticated and trustworthy models. By acting now, healthcare insurance providers can meet today’s expectations, prepare for tomorrow’s regulations, and ensure that the promise of AI is realized without compromising equity, integrity, or consumer trust.
To begin, insurers can prioritize by mapping the top three AI models in active use for bias risks, build an evidence pack that demonstrates compliance and fairness testing, and set up continuous monitoring to detect drift. These early actions create a defensible foundation for regulators, strengthen consumer trust, and build the internal momentum needed to expand governance across the enterprise. By starting strategically, insurers can position themselves to meet regulatory expectations with today’s rules and lead in tomorrow’s market.
1. New York State Department of Financial Services. Insurance Circular Letter No. 7 (2024): Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing. 2024. Available at: https://www.dfs.ny.gov/industry-guidance/circular-letters/cl2024-07
2. Colorado Division of Insurance. Regulation 10-1-1 Governance and Risk Management Framework Requirements for Life Insurers’ Use of External Consumer Data and Information Sources, Algorithms, and Predictive Models. 2023. Available at: https://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=11153&fileName=3%20CCR%20702-10
3. National Association of Insurance Commissioners. Principles on Artificial Intelligence. NAIC. 2020. Available at: https://content.naic.org/sites/default/files/inline-files/AI%20principles%20as%20Adopted%20by%20the%20TF_0807.pdf
4. Zink A, Rose S. Identifying Undercompensated Groups Defined by Multiple Attributes in Risk Adjustment. BMJ Health & Care Informatics. 2021 Sep 17;28(1):e100414.
5. Filabi A, Duffy S. AI-Enabled Underwriting Brings New Challenges for Life Insurance: Policy and Regulatory Considerations. Journal of Insurance Regulation. 2021 Aug 1;40(8).
6. Barocas S, Hardt M, Narayanan A. Fairness and Machine Learning: Limitations and Opportunities. MIT press; 2023 Dec 19.
7. Debevoise & Plimpton LLP. Europe’s Regulatory Approach to AI in the Insurance Sector. May 6, 2025. Available at: https://www.debevoise.com/insights/publications/2025/05/europes-regulatory-approach-to-ai-in-the-insurance
8. Organisation for Economic Co-operation and Development. OECD AI Principles. Originally adopted May 2019, updated May 2024. Available at: https://www.oecd.org/en/topics/sub-issues/ai-principles.html
9. Monetary Authority of Singapore. Principles to Promote Fairness, Ethics, Accountability and Transparency (FEAT). 2018. Available at: https://www.mas.gov.sg/-/media/mas/news-and-publications/monographs-and-information-papers/feat-principles-updated-7-feb-19.pdf
10. Australian Prudential Regulation Authority (APRA). APRA Corporate Plan 2025-26. 2025. Available at: https://www.apra.gov.au/apra-corporate-plan-2025-26
11. European Union. Artificial Intelligence Act. Adopted August 1, 2024; phased enforcement through August 2026. Official text available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1689
Secure your platforms and products to drive insights from AI and accelerate healthcare transformation.