AI Governance for Small Practices: A Realistic Framework

Every AI governance article you've read was written for a 500-bed hospital with a CMIO, a legal department, and a six-figure consulting budget. That's useless for a 5-physician family practice in suburban Ohio.

This framework is designed for small practices — groups of 1-20 physicians who are already using AI tools informally and need to formalize it before a compliance event forces them to.

The 2-Hour Governance Setup

You need exactly four things:

1. An AI Tool Inventory (30 minutes)

List every AI tool anyone in your practice uses — including personal tools. This is usually surprising. Most practices find 3-5 tools they didn't know staff were using.

• •For each tool, document:
• •Tool name and vendor
• •What it's used for
• •Whether it touches patient data
• •Whether there's a BAA in place
• •Who authorized its use

2. A Decision Rule (15 minutes)

Create a simple 3-tier classification:

Green (use freely): AI tools that never touch patient data. Examples: scheduling optimization, billing code lookup, general medical education.

Yellow (use with caution): AI tools that process patient data under a signed BAA. Examples: EHR-integrated scribes, approved clinical decision support. Requires documentation of use.

Red (do not use): Consumer AI tools with patient data, any tool without a BAA, any tool making autonomous clinical decisions. No exceptions.

3. A Review Cadence (15 minutes)

• •Once per quarter, spend 30 minutes reviewing:
• •Any new tools added to the inventory
• •Any incidents or near-misses
• •Any staff concerns about AI tools
• •Whether existing BAAs are still current

4. A Staff Agreement (1 hour)

• •A one-page document every staff member signs acknowledging:
• •They will not use Red-tier tools with patient data
• •They will document Yellow-tier tool usage
• •They will report any AI-related incidents
• •They understand that AI output requires human review

That's It

No committee. No 40-page policy document. No consultant. Four deliverables, two hours, and you're ahead of 90% of practices your size.

The goal isn't perfection — it's documentation. When (not if) a payer, carrier, or regulator asks about your AI practices, you have a written answer instead of a shrug.