The AAO recently helped stop a proposed artificial intelligence policy that could have changed how AI is used in healthcare and potentially influenced legislation in states across the country.
The American Legislative Exchange Council, or ALEC, recently considered the Clinical AI Services Act, proposed model legislation process. That decision came after the AAO submitted a letter on July 23 urging ALEC’s Health & Human Services Task Force not to advance the proposal in its current form and raised significant concerns about the proposal. Simply put, the proposal would authorize certain AI systems to deliver clinical services independently and create a framework governing their licensure, oversight, and reimbursement.
Why does this matter?
Stopping the proposal at this stage was especially important because ALEC develops model policies that state lawmakers may later adapt into legislation. Although ALEC does not enact laws itself, an approved model can influence bills introduced in multiple states. Had the Clinical AI Services Act advanced, its language could have shaped clinical AI policy across the country.
Protecting Patients and Professional Accountability
The AAO opposed the proposal because it conflicted with one of the association’s core principles in Responsible Integration of Artificial Intelligence in Orthodontic Clinical Practice, which had already established a specialty-specific framework grounded in the Human-in-Command principle.
At issue is not whether artificial intelligence belongs in health care. AI already has valuable applications in orthodontics and will continue to influence diagnosis, imaging, treatment planning, patient monitoring, and practice operations.
The more fundamental question is: Who remains responsible when AI affects a clinical decision?
Keeping a Human in Command
The paper’s central principle is clear: A licensed health care professional must remain responsible and accountable for every clinical decision affecting a patient’s health.
AI systems can perform increasingly sophisticated functions that support clinical care. However, a licensed orthodontist should nevertheless retain authority over how those systems are used and responsibility for the care provided.
Orthodontic treatment requires the integration of imaging, examination findings, patient history, treatment objectives, informed consent, professional experience, and the individual needs of the patient. AI may contribute to that process, but it should not replace the professional judgment of the clinician responsible for bringing those factors together.
The proposal also represented a departure from the longstanding state licensure framework through which health care professionals are held to defined standards of education, competency, ethics, and professional conduct. The AAO believes legislation governing clinical AI should reinforce that framework rather than create a separate path around it.
The American Dental Association also submitted comments outlining legal, regulatory, and governance concerns. The AAO’s letter reinforced many of those concerns while providing an additional clinical perspective specific to orthodontics, informed by members’ experience using advanced technologies in patient care and by the principles in the AAO’s AI position paper. The AAO also coordinated with the Academy of General Dentistry throughout the ALEC review process.
Advocacy Before Legislation Is Introduced
This type of advocacy may receive less attention than work surrounding a bill already moving through Congress or a state legislature.
Once model language is approved and begins appearing in state legislatures, its basic assumptions may be more difficult to change. The AAO’s proactive engagement gives the specialty an opportunity to identify potential consequences and offer clinical expertise while policy is still taking shape.
That work requires established relationships with key stakeholders and elected officials, ongoing monitoring of proposals developing outside traditional legislative channels, and the ability to bring the specialty’s perspective to those considering them.
This work reflects the broader role of AAO Advocacy, which monitors emerging policy issues, maintains relationships with decision-makers, and draws on the expertise of members, volunteer leaders, and organized dentistry partners. That sustained work helps ensure the orthodontic perspective is represented early, when there is still an opportunity to shape the outcome.
An individual orthodontist may share the AAO’s concerns about independently licensed AI providers. No individual member or practice, however, can reasonably monitor every model policy, evaluate its clinical and legal implications and coordinate a response with potential relevance to multiple states.
A Unified Voice Matters
This is exactly why AAO advocacy is so important. With ALEC expected to revisit the issue at its December 2026 meeting, the AAO and its coalition partners will continue working to shape revised language that preserves professional accountability and patient protections.
That is the power of a unified voice: not only preventing language that could undermine patient safety and professional accountability from advancing but also giving orthodontists a meaningful role in shaping what comes next. By identifying issues early and bringing the specialty’s expertise to policymakers, the AAO helps protect both the patient and the specialty.
