AI Use Policy

AI Use Policy – Spencer Health

  1. Spencer Health’s commitment to the legal, ethical and responsible use of AI:
    • Spencer Health (“us”, “we” or “our”) is committed to using AI to improve the health outcomes of patients, in a way that is legal, ethical and responsible.
    • The purpose of this AI Policy is to create a set of guiding principles that comply with the legal and ethical obligations that govern the responsible use of AI tools by clinicians.
    • Spencer Health takes the privacy of clients’ information seriously, and our Privacy Policy sets out how we collect and treat your Personal Information and Sensitive Information. Our Privacy Policy and this AI Policy operate together.
    • This AI Policy deals with both the general principles Spencer Health is committed to in order to ensure the legal, ethical and responsible adoption and use of AI tools, as well as guidelines for the AI tools used by Spencer Health to ensure the use of those tools is of benefit to clients and promotes client health outcomes while protecting client data and information.
  2. Definitions

In this Policy:

  • “AI” stands for artificial intelligence and refers to the capability of a machine to imitate intelligent human behaviour.
  • “AI tool” describes any software program that uses AI to perform tasks.
  • “Large language model” or “LLM” is a type of artificial intelligence model designed to understand, generate or manipulate human language. They are trained on very large amounts of text data and use statistics and machine learning techniques to generate text based on the input they receive.
  • “Generative AI” is a type of machine learning model that generates new content (for example, text, images, videos etc) as outputs.
  1. Spencer Health’s Statement of Values and Ethics in the use of AI
    • Spencer Health believes that with appropriate policies in place, AI can support the delivery of healthcare outcomes.
    • Spencer Health believes that human-delivered care must never be replaced by AI, but that AI has the potential to assist in care delivery and improve client outcomes. AI is seen by Spencer Health as a means to achieving the goal of improved healthcare but can only support the psychologist and patient to reach this goal.
    • Improved patient health and well-being will always be the primary and guiding focus of the adoption of all AI tools by Spencer Health. AI tools will only be adopted by Spencer Health where this will genuinely contribute to improving health outcomes of patients.
    • The adoption and implementation of all AI tools by Spencer Health will be patient-centred and used to benefit patients’ health and well-being.
    • AI must never compromise the clinician’s clinical independence or professional autonomy.
    • A registered health practitioner or otherwise appropriately qualified clinician must always be ultimately responsible for decisions and communications and should have meaningful involvement at all stages of the patient journey.
    • All AI tools implemented by Spencer Health must uphold and support the patients’ rights to make their own informed healthcare decisions.
    • It is important to Spencer Health to be accountable and transparent to patients, the health profession and the wider community about the use of AI in supporting clients’ healthcare outcomes.
    • The application of AI in health care must never lead to greater health inequalities for any population.
    • Patients have the right to refuse to be involved in the use of AI at any time
    • AI tools will only be adopted by Spencer Health after first establishing robust and effective frameworks for managing risks which ensure patient safety and guarantee the privacy for all involved. These frameworks will be bespoke to the AI tool being adopted, and regularly and vigorously reviewed.
    • Spencer Health will never establish protocols where the clinical independence of the clinician is undermined by AI or the final decision is made by a person in a non-clinical role with the aid of AI.
    • AI tools will not be used by administrative (non-clinical) staff.
  2. Use of patients data and information
    • As outlined in our Privacy Policy, Spencer Health may receive and store your Data.
    • Spencer Health is committed to the protection of the privacy of patient health information.
    • Spencer Health will always use AI in accordance with the Privacy Policy in place at the relevant time.
    • Spencer Health will only adopt and use AI tools following a careful review of that tool’s approach to privacy, and has adopted a protocol of regular checking the tool to ensure there has been no material change to the way client data and information is stored, used and deleted.
    • AI tools will not be used, disclosing a client’s personal or sensitive information, without written consent from the client.
    • The disclosure of Health Information must be limited to initiatives that exclusively aim to provide the health service to the client and/or improve the clients health outcomes.
  3. Complaints about our AI policy
    • If you have any complaints about our AI practices, please feel free to send in details of your complaints to:

Shannon Lopez - Principal Clinical Psychologist | shannong@spencerhealth.com.au

  • We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
  1. Changes to our AI policy
    • Our AI Policy is subject to change.
    • Spencer Health may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website https://spencerhealth.com.au/ or through distribution by email. Please check back from time to time to review our AI Policy.
  2. Current AI tools in use
    • Spencer Health will maintain a list of AI tools in regular use by its clinicians.
    • At present, Spencer Health uses:
  • Novonote by Novopsych
    • A summary of each AI tool adopted and how it is used is set out below.
    • Use of AI tools that do not meet Australian guidelines or standards, whose data is not stored in Australia, or which are not HIPAA compliant, are not suitable for use at Spencer Health.

NovoNote AI Scribe by NovoPsych

What NovoNote AI Scribe by NovoPsych (NovoNote) does:

NovoNote is an AI scribe tool that produces an AI generated note or report from a live or recorded client session/s with a psychologist. These summaries are created using templates, which are able to be modified and changed to suit the user and purpose, and are then able to by copied and pasted into the practice management software. The recording of the session is then deleted after a set amount of time, determined by the user (7 business days).

Ordinary uses will include

·       Creating file notes for clients based on therapy sessions and assessment sessions

·       Creating Medicare letters for Medicare compliance to GPs

·       To create support letters for clients

·       To complete background history for clients for assessment reports

·       To write minutes for internal meetings, eg team meetings.

Why NovoNote has been adopted:

NovoNote will assist clinicians by recording all relevant information during a consultation. NovoNote will ensure that the practitioner’s focus will be on the client, and not the technology. NovoNote AI will enable the practitioner to focus on engaging with the client, providing better eye contact and open communication signals, as well as the delivery of psychological interventions, which will assist the client to establish a better therapeutic rapport with the practitioner and lead to better client outcomes. NovoNote AI will also reduce the time spent by the practitioner in preparing records following the consultation, which will instead be allocated to a larger focus on treatment planning and preparation for the psychological intervention.

What NovoNote will be used for:

Ordinary uses will include creating file notes for clients based on therapy sessions and assessment sessions; creating Medicare letters for Medicare compliance to GPs; create support letters for clients; to complete background history for clients for assessment reports as well as to write minutes for internal meetings, for example team meetings and to distribute for internal Spencer Health purposes.

NovoNote will only be used by fully registered psychologists employed by Spencer Health as employees, excluding provisional psychologists and administration staff at Spencer Health.

What NovoNote will not be used for:

NovoNote cannot and will not be used to make decisions in relation to client care, including treatment plans, full assessment reports or clinical formulations. NovoNote will not be used by administrative or non-clinical staff. The health practitioner will view the draft of the clinical note on the same day as the appointment, as per existing policies of Spencer Health.

Each month at regular employee check-ins with the Clinical Services Manager, the Clinical Services Manager will review a random selection of notes completed by the health practitioner in the first month, and provide an audit of the accuracy of the notes with the health practitioner.

Written consent:

NovoNote will only be used with clients who have provided written consent for the use. Clients are able to opt-in to each component of NovoNote’s scribe capabilities, including transcription, AI note generation, or both.

Accountability:

The clinician using NovoNote will be responsible for reviewing each clinical note for accuracy and sign off on the note once adopted. Each note will include the sign off of- “Case notes (or other) created with the use of NovoNote by NovoPsych and reviewed and adopted by [clinician’s name]. I, [Clinician’s Name] declare that my clinical judgement was used in the creation of this note.”

NovoNote cannot and will not be used to make decisions in relation to client care, including treatment plans, full assessment reports or clinical formulations. NovoNote will not be used by administrative or non-clinical staff.

Key Points Notes:

The key point notes are an important safeguard in ensuring the notes generated by NovoNote are accurate and record the important parts of all client consultations. During the consultation, the practitioner will make a record of the key points that must be included in the client’s records. The practitioner will use these key points when reviewing the note prepared by NovoNote, to ensure that the note is both accurate and complete. In this way, each note will have an independent human lead review to ensure that case notes created by NovoNote are at least as good as the notes that would have been recorded by the practitioner during the client consultation.

Specific risk mitigation policies in place:

The clinician using NovoNote will be responsible for reviewing each clinical note for accuracy and sign off on the note once adopted. Each note will include the sign off of- “Case notes (or other) created with the use of NovoNote by NovoPsych and reviewed and adopted by [Clinician’s Name]. 1, [Clinician’s Name] declare that my clinical judgement was used in the creation of this note.”

Transparency:

For internal record-keeping purposes, content created with the assistance of NovoNote will be labelled as such, by including a note similar to the following: “Minutes created with the use of NovoNote by NovoPsych and reviewed and adopted by [Clinician’s Name]”.

Data storage by NovoNote:

NovoNote will temporarily store a copy of patient information in servers in Australia. Although the data can be stored for longer periods of time, Spencer Health will set a mandatory timeframe for all data to be deleted within 7 calendar days]. NovoNote]has been carefully selected by Spencer Health as it complies with the Australian Privacy legislation and the Australian Privacy Principles.

Authorised Use:

Only clinicians who are employees of Spencer Health will have access to and use NovoNote. Administrative staff will not use the tool and will not have access to the system.

Assessment and Review schedule:

Spencer Health is committed to a regular assessment and review of the adoption and use of NovoNote. In addition to the contemporaneous review for accuracy and completeness conducted. The Principal Clinical Psychologist will conduct a comprehensive random audit every 6 months. The purposes of the random audit include confirmation that this AI Policy is being adhered to, that the information contained in the AI policy in relation to each AI tool adopted is correct and up-to-date.