Three obligations, three dates — all current
The digital scribe ruling
The TGA clarified that pure transcription is not a medical device — but software that analyses or interprets a consultation (summaries with diagnostic, prognostic or treatment content) is one, and requires ARTG inclusion. Software-based medical devices are on the TGA's stated compliance priorities for 2026–27, and it has said it is moving into enforcement against deployed, non-approved tools.
Ask: which side of the TGA's line does our scribe sit on — and can we show how we decided?
Your professional obligations
Ahpra's guidance on AI in healthcare puts accountability squarely on the practitioner: you must understand the tools you use, tell patients when AI processes their information, and obtain consent before it does. Your indemnity insurer cares too — Avant has warned members that broad indemnity clauses in scribe vendor terms can undermine practitioner cover.
Ask: have we read our scribe vendor's indemnity clause, and does our patient consent actually cover AI processing?
The automated decision-making deadline
From 10 December 2026 your privacy policy must disclose automated decisions that significantly affect people's rights or interests — the kinds of personal information used and the kinds of decisions made. The OAIC has signalled a broad reading, covers rule-based scripts and spreadsheets as well as AI, and began proactive privacy-policy sweeps in January 2026.
Hard date: 10 December 2026. A privacy policy written before this obligation existed will not comply by accident.
NDIS providers: governance as audit evidence
The Commission's February 2026 AI transparency statement treats provider use of AI as legitimate and expected — provided it is governed properly. With mandatory registration extending to SIL and platform providers from 1 July 2026, "governed properly" becomes something you evidence at audit, mapped to the NDIS Practice Standards.
Ask: if our auditor asked where AI touches participant records and who is accountable, could we hand them a document?
Fixed-price packages, practice-sized
No enterprise engagement, no day rates. A defined deliverable your practice manager can action and your auditor, insurer or the OAIC can read. The value is not the documents — free templates exist — it is mapping them to your tools, your consent flow and your audit evidence.
AI-Safe Practice Package
- AI use policy aligned to Ahpra + ACSQHC guidance
- Patient consent wording for AI processing
- Scribe vendor due-diligence, incl. TGA classification check and indemnity-clause review
- Privacy policy ADM update — compliant before 10 Dec 2026
- Staff one-pager: what AI may and may not touch
NDIS AI Governance Evidence Pack
- AI use policy + risk register for participant-facing and admin AI
- Evidence mapping to the NDIS Practice Standards
- Incident and complaint handling where AI touched records
- Privacy policy ADM update — compliant before 10 Dec 2026
- Audit-day summary pack for your assessor
Running more than a practice?
Multi-site groups, aged care providers with home-care and allied arms, and boards wanting the full picture: the AI Risk Assessment scores your organisation across 8 governance dimensions — $4,900, board-ready in 5 business days or it's free.
Not sure which side of the TGA's line you're on?
Send the name of your scribe or AI tool and we'll tell you in plain English what it triggers — no charge, no obligation.
Ask the question