Two bills were passed by the 2025 Texas legislature that establish clear disclosure rules for physicians using artificial intelligence (AI) when seeing patients. These rules are currently in effect in Texas. (1)

Senate Bill 1188 states that AI use in a diagnostic capacity is only allowed if:

• the practitioner is acting within the scope of their license;  
• the particular use of AI is not prohibited by law;
• the practitioner reviews all AI-generated records consistent with Texas Medical Board standards; and
• the practitioner discloses their use of AI technology to patients.

Noncompliance can result in financial penalties and license suspension or revocation for repeat offenders.

House Bill 149 — the Texas Responsible Artificial Intelligence Governance Act — requires health care providers to inform patients or their guardians when AI systems are being used in their treatment “not later than the date of service or treatment,” or as soon as reasonably possible in an emergency. These disclosures must be clear, conspicuous, and written in plain language.

Both rules must be followed in conjunction with existing HIPAA regulations. (1)

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Sample AI disclosure statements

According to the Medical Group Management Association, effective AI disclosure statements include the following elements:

• a description of the AI tools being used;
• how the AI tools are used, emphasizing that health care providers review outputs before action is taken;
• the data (including PHI) the AI tools will process or collect, and how that data will be protected; and
• a way for patients to ask questions or address concerns. (2)

To help develop disclosures that are “clear, conspicuous, and written in plain language,” consider the following sample disclosure statements. Any disclosure language should be adapted to fit your practice and specific use of AI. Physicians may wish to consult with an attorney if the AI use is complex, or if assistance is needed to develop disclosure language.

Sample AI disclosure — ambient scribes

“[Practice name] uses generative AI transcription technology to generate medical notes and update a patient’s medical chart in real-time. Natural language processing allows the transcription software to analyze and dictate human conversations as they occur, similar to a physician’s scribe. If a patient opts in to this feature, the technology can be used during or after the patient’s visit when a doctor prepares after-visit summaries and updates a patient’s chart.

Data collected can help staff recommend ICD-10 codes for medical billing purposes and can be integrated into a patient’s electronic health record. The attending provider must review the transcription for quality assurance purposes before the notes are added to the patient’s medical chart. The vendor is HIPAA compliant and uses two-factor authentication to prevent unauthorized access. If you would like to use this feature, you must opt in here. Patients must provide consent for this feature on an annual basis.” (3)

Sample AI disclosure — diagnostic and imaging tools

The findings and impressions of the radiology report you will receive are those of the interpreting radiologist. Your radiologist may use artificial intelligence (AI) software as a supportive tool during the interpretation process. This does not replace the radiologist, who is responsible for reading your images. The AI software we use complies with HIPAA privacy and security requirements to protect your health information.

This disclosure is provided in accordance with Texas law to ensure transparency about technologies used in your care. If you have questions about how AI is used in interpreting your imaging studies, please contact us at [contact information.] (4)

Sample AI disclosure — multiple tools

“At [Practice Name], we are committed to providing you with the best possible treatment. To help us manage our practice efficiently and enhance our services, we use technology, including certain artificial intelligence (AI) tools.

This document explains how we use these tools and asks for your consent to use them as part of your treatment. Your privacy, confidentiality, and the quality of your treatment remain our highest priorities.” (5)

Sources

1. Pierce A. Physicians must disclose use alongside existing HIPAA requirements, per state laws. Texas Medical Association. December 30, 2025. Available at  https://www.texmed.org/TexasMedicineDetail.aspx?id=67060. Accessed February 2, 2026.
2. Good C. Sample patient consent form for using artificial intelligence for dictation, transcription. Medical Group Management Association. April 2, 2024. Available at https://www.mgma.com/member-tools/sample-patient-consent-form-for-using-ai#. Accessed February 3, 2026.
3. Bloomberg Law. Patient opt-in consent form (generative AI). Available at https://www.bloomberglaw.com/external/document/XF6H2E20000000/health-care-transactions-sample-document-patient-opt-in-consent-. Accessed February 3, 2026.
4. Glenning J, Gualtieri L. Patient perspectives on artificial intelligence in medical imaging. J Particip Med. 2025 Jul 28;17:e67816. doi: 10.2196/67816. PMID: 40720822; PMCID: PMC12304780. Available at https://pmc.ncbi.nlm.nih.gov/articles/PMC12304780/. Accessed February 3, 2026.
5. Simple Practice. How to inform clients about using AI notes in your practice. July 11, 2025. Available at https://www.simplepractice.com/resource/inform-clients-using-ai-notes/. Accessed February 3, 2026.