Meeting Packet — Insurance & Banking Subcommittee, HB 505 and HB 527 (December 9, 2025)
Summary
A meeting packet of the Insurance & Banking Subcommittee of the House of Representatives, with a notice for Tuesday, December 9, 2025, from 12:30 PM to 2:30 PM. The notice lists consideration of HB 505 Virtual Currency Kiosks and HB 527 Mandatory Human Reviews of Insurance Claim Denials. The bill analysis of HB 505 states that the bill requires a fraud warning on kiosk screens, limits transactions to $2,000 per day for new customers and $10,500 per day for existing customers, and requires a refund within 72 hours under certain conditions. It gives an effective date of January 1, 2027. The packet closes with pages of an amendment to HB 527.
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“Meeting Packet — Insurance & Banking Subcommittee, HB 505 and HB 527 (December 9, 2025).”
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Insurance & Banking Subcommittee
Tuesday, December 9, 2025
12:30 PM - 2:30 PM
Morris Hall (17 HOB)
Meeting Packet
Daniel Perez Bradford Yeager
Speaker Chair
Committee Meeting Notice
HOUSE OF REPRESENTATIVES
Insurance & Banking Subcommittee
Start Date and Time: Tuesday, December 09, 2025 12:30 PM
End Date and Time: Tuesday, December 09, 2025 02:30 PM
Location: Morris Hall (17 HOB)
Duration: 2.00 hrs
Consideration of the following bill(s):
HB 505 Virtual Currency Kiosks by Owen, Daley
HB 527 Mandatory Human Reviews of Insurance Claim Denials by Cassel
NOTICE FINALIZED on 12/02/2025 4:01PM by Young.Kimberly
12/02/2025 04:01:55PM Leagis ® Page 1 of 1
HB 505
FLORIDA HOUSE OF REPRESENTATIVES
BILL ANALYSIS
This bill analysis was prepared by nonpartisan committee staff and does not constitute an official statement of legislative intent.
BILL #: HB 505 COMPANION BILL: SB 198 (Rouson)
TITLE: Virtual Currency Kiosks LINKED BILLS: None
SPONSOR(S): Owen and Daley RELATED BILLS: None
Committee References
Insurance & Banking Commerce
SUMMARY
Effect of the Bill:
The bill requires the owner or operator of virtual currency kiosks to warn customers of the risk of fraud. The bill
limits kiosk transactions for new customers to $2,000 per day and for existing customers to $10,500 per day. The
bill requires the owner or operator of virtual currency kiosks to provide customers with a receipt containing
contact information for the owner or operator, transaction details, a statement of the owner’s or operator’s liability,
and the owner’s or operator’s refund policy. The bill requires the owner or operator to issue a refund within 72
hours under certain conditions. The bill permits the Financial Services Commission to adopt rules.
Fiscal or Economic Impact:
The bill has an indeterminate impact on the private sector and state government.
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ANALYSIS
EFFECT OF THE BILL:
Disclosure requirement
The bill provides that a “virtual currency kiosk” means an electronic terminal that acts as a mechanical agent of the
owner or operator, enabling the owner or operator to facilitate the exchange of virtual currency for fiat currency or
other virtual currency on behalf of a customer. (Section 1).
The bill requires the owner or operator of a virtual currency kiosk to clearly display a disclosure on the kiosk
screen before a customer may initiate a virtual currency transaction. (Section 1).
The disclosure must state:
“WARNING: CONSUMER FRAUD OFTEN STARTS WITH CONTACT FROM A STRANGER. IF YOU HAVE
BEEN DIRECTED TO THIS MACHINE BY SOMEONE CLAIMING TO BE A GOVERNMENT AGENT, BILL
COLLECTOR, LAW ENFORCEMENT OFFICER, OR ANYONE YOU DO NOT KNOW PERSONALLY, STOP
THIS TRANSACTION IMMEDIATELY AND CONTACT YOUR FINANCIAL ADVISOR OR LOCAL LAW
ENFORCEMENT.” (Section 1).
Transaction limits
The bill prohibits owners or operators of virtual currency kiosks from allowing new customers to transact more
than $2,000 per calendar day and from allowing existing customers to transact more than $10,500 per calendar
day. These limits apply regardless of whether the customer engages in a single transaction or multiple
transactions. (Section 1).
STORAGE NAME: h0505.IBS
DATE: 12/3/2025
1
HB 505
The bill defines “new customer” as a customer who has transacted with the owner or operator of a virtual currency
kiosk for less than 7 days. The bill defines “existing customer” as a customer who has transacted with the owner or
operator of a virtual currency kiosk for 7 or more days. (Section 1).
Receipt requirement
The bill requires the owner or operator of virtual currency kiosks to provide customers with electronic receipts,
which must include the following information:
Name and contact information of the owner or operator, including a toll-free telephone number;
Date, time, value, and type of the transaction;
Transaction hash and each wallet used;
Total fee charged;
Exchange rate, if applicable;
Statement of the owner’s or operator’s liability, if any, for non-delivery or delayed delivery of the currency;
and
Refund policy of the owner or operator. (Section 1).
The bill defines “transaction hash” as a unique identifier consisting of a string of characters which provides a
verifiable record that a transaction has been confirmed and added to the blockchain.1 (Section 1).
The bill defines “wallet” as hardware or software that enables customers to store and use digital currency. (Section
1).
Refund requirement
The bill requires the owner or operator of virtual currency kiosks to issue a full refund for a customer’s first virtual
currency transaction within 72 hours if all of the following conditions are met:
The customer transferred the virtual currency to a wallet outside of the United States;
The customer contacts both the owner or operator of the virtual currency kiosk and a law enforcement or
governmental agency regarding the fraudulent nature of a transaction within 60 days; and
The customer provides proof of fraud, such as a police report or notarized affidavit. (Section 1).
Effective date
The bill provides an effective date of January 1, 2027. (Section 2).
RULEMAKING:
The bill authorizes the Financial Services Commission to adopt rules to implement the bill.
Lawmaking is a legislative power; however, the Legislature may delegate a portion of such power to executive
branch agencies to create rules that have the force of law. To exercise this delegated power, an agency must
have a grant of rulemaking authority and a law to implement.
FISCAL OR ECONOMIC IMPACT:
STATE GOVERNMENT:
There is an indeterminate impact on state government, to the extent that the Financial Services Commission may
incur costs to promulgate rules.
1 The bill defines “blockchain” as a mathematically secured, chronological, decentralized, distributed, and digital ledger or
database that consists of records of transactions that cannot be altered retroactively.
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HB 505
PRIVATE SECTOR:
There is an indeterminate impact on the private sector. This bill may reduce the financial losses associated with
virtual currency kiosk scams. However, virtual currency kiosk businesses may incur additional expenditures to
comply with the bill’s provisions.
RELEVANT INFORMATION
SUBJECT OVERVIEW:
Virtual Currency
Virtual currency is a digital representation of value that functions as a medium of exchange but lacks legal tender
status.2 In some environments, virtual currency operates like “real” currency3 (i.e., the coin and paper money of the
United States or of any other country that is designated as legal tender, circulates, and is customarily used and
accepted as a medium of exchange in the country of issuance).4 Virtual currency that has an equivalent value in real
currency, or that acts as a substitute for real currency, is referred to as “convertible” virtual currency. 5 Bitcoin is
one example of a convertible virtual currency, as it can be digitally traded between users and can be purchased for,
or exchanged into, U.S. dollars, Euros, and other real or virtual currencies.6
Virtual currencies generally operate on networks of computers (nodes) that enable, validate, and record
transactions on a distributed digital ledger (blockchain).7 To transfer an asset on a blockchain, the transferor uses
an alphanumeric code known only to the transferor (a private key) to create a request that the network software
validate a new ledger entry, which assigns control of the asset to the recipient.8 Once the network has validated this
transfer, the ledger is updated and the recipient may transfer the asset to another recipient using their own private
key.9 Ledger entries are cryptographically secured, and accounts on a blockchain are identified by alphanumeric
‘‘public keys’’ rather than by personal names.10 Virtual currency wallets are interfaces that store and transfer
virtual currency.11
Virtual Currency Kiosks
Virtual currency kiosks are physical ATM-like machines that allow users to buy or exchange virtual currency.12
Virtual currency kiosks generate revenue for their owner or operator through the collection of fees and are
generally located in businesses such as convenience stores, gas stations, cafes, and supermarkets.13
2 S. 560.103(36), F.S.
3 Often referred to as “fiat” currency.
4 IRS, Digital assets, https://www.irs.gov/filing/digital-assets (last visited Dec. 1, 2025).
5 Id.
6 Id.
7 Office of the Federal Register, National Archives and Records Administration, Requirements for Certain Transactions Involving
Convertible Virtual Currency or Digital Assets, GovInfo, (Dec. 23, 2020), https://www.govinfo.gov/app/details/FR-2020-12-
23/2020-28437/summary (last visited Dec. 1, 2025).
8 Id.
9 Id.
10 Id.
11 FinCEN, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies, (May 9,
2019), https://www.fincen.gov/system/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf (last visited Dec.
1, 2025).
12 FinCEN, Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity, (Aug. 4, 2025),
https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf (last visited Dec. 1, 2025).
13 FTC, Bitcoin ATMs: A payment portal for scammers, (“FTC Report”) (Sept. 3, 2024), https://www.ftc.gov/news-events/data-
visualizations/data-spotlight/2024/09/bitcoin-atms-payment-portal-scammers (last visited Dec. 1, 2025).
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HB 505
To engage in a transaction, a customer enters the address of the virtual wallet that will receive the purchased
virtual currency.14 The address could be the customer’s own virtual wallet, or that of a third party.15 The wallet
address is usually embedded in a quick-response (QR) code, which is a barcode that can be scanned and read with
a kiosk camera.16 The customer then inserts cash or a debit or credit card into the machine to finalize the
transaction.17
As of December 2025, there are reportedly 37 operators and a total of 3,150 kiosks in Florida.18
According to the Office of Financial Regulation (OFR), the Federal Bureau of Investigation and Federal Trade
Commission have received Florida-based complaints involving virtual currency kiosk fraud, totaling well over $33
million in alleged victim losses between January 2020 and December 2025.19
State Regulation
The OFR is responsible for all activities of the Financial Services Commission relating to the regulation of banks,
credit unions, other financial institutions, finance companies, and the securities industry.20 The Division of
Consumer Finance within OFR licenses and regulates various aspects of the non-depository financial services
industries, including money services businesses.21
A money services business is, “any person located in or doing business in this state, from this state, or into this
state from locations outside this state or country who acts as a payment instrument seller, foreign currency
exchanger, check casher, or money transmitter.”22 Money services businesses must be licensed with OFR.23
Payment instruments do not include virtual currency.24 However, money transmitters include those who for the
purpose of acting as an intermediary, receive or transmit virtual currency.25 Thus, the owner or operator of a
virtual currency kiosk may constitute a money services business if it acts as a money transmitter.
Florida does not have a separate regulatory regime for virtual currency kiosk businesses. If the kiosk only conducts
direct peer-to-peer transactions, meaning the owner or operator sells virtual currency from its own inventory
directly to customers without a third party, then the owner or operator does not require licensure.26 However, if
the kiosk acts as an intermediary, meaning it facilitates the transmission of funds from one party to a third party,
then the kiosk may act as a money transmitter, and thus the owner or operator would constitute a money services
business and would need a license from OFR.27
14 FinCEN, Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity, (Aug. 4, 2025),
https://www.fincen.gov/system/files/2025-08/FinCEN-Notice-CVCKIOSK.pdf (last visited Dec. 1, 2025).
15 Id.
16 Id.
17 Id.
18 Coin ATM Radar, Bitcoin ATMs in Florida, available at https://coinatmradar.com/state/10/bitcoin-atm-florida/ (last visited
Dec. 2, 2025).
19 Email from Jason Holloway, Director of Fintech Policy, Office of Financial Regulation, RE: HB 505 – Inquiry regarding virtual
currency kiosks (Dec. 2, 2025).
20 S. 20.121(3)(a)2., F.S.
21 Office of Financial Regulation, Division of Consumer Finance, https://flofr.gov/divisions-offices/division-of-consumer-
finance (last visited Dec. 2, 2025).
22 S. 560.103(23), F.S.
23 S. 560.125, F.S.
24 S. 560.103(29), F.S.
25 S. 560.103(24), F.S.
26 Florida Office of Financial Regulation, Biennial Report December 2024, p. 32, available at https://flofr.gov/docs/default-
source/documents/biennial-report-2024.pdf?sfvrsn=4030c57c_1 (last visited Dec. 2, 2025).
27 Id.
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HB 505
Federal Regulation
The Financial Crimes Enforcement Network (FinCEN), a bureau of the United States Department of Treasury, is
responsible for safeguarding the financial system from illegal use, combatting money laundering and related
crimes, and promoting national security.28 Unless an exception applies, a money services business must register
with FinCEN.29 Under federal law, money services businesses include persons who provide money transmission
services.30 Money transmission involves the “acceptance of currency, funds, or other value that substitutes for
currency and the transmission of currency, funds, or other value that substitutes for currency to another location
or person by any means” or “any other person engaged in the transfer of funds.”31 According to OFR, virtual
currency kiosk businesses that are not required to register with OFR as a money services business would still need
to register with FinCEN.32
Virtual currency kiosks that engage in money transmission are considered money services businesses under the
Bank Secrecy Act which must comply with registration and reporting requirements.33 Notwithstanding these
requirements, limited information on virtual currency kiosks is collected, which has made it difficult for federal
agencies such as FinCEN to identify and track virtual currency kiosks.34 The United States Government
Accountability Office (GAO) reports that only 164 of the estimated 297 kiosk operators in the United States were
registered.35
BILL HISTORY
STAFF
DIRECTOR/ ANALYSIS
COMMITTEE REFERENCE ACTION DATE POLICY CHIEF PREPARED BY
Insurance & Banking Brackett Highsmith
Subcommittee
Commerce Committee
28 31 U.S.C. §. 310.
29 31 C.F.R. §. 1022.380(a).
30 31 C.F.R. §. 1010.100(ff)(5).
31 31 CFR §. 1010.100(ff)(5)(i)(A).
32 Email from Jason Holloway, Director of Fintech Policy, Office of Financial Regulation, RE: HB 505 – Inquiry regarding virtual
currency kiosks (Dec. 2, 2025).
33 FinCEN, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies, (May 9,
2019), https://www.fincen.gov/system/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf (last visited Dec.
1, 2025).
34 Id.
35 The GAO, Virtual Currencies Additional Information Could Improve Federal Agency Efforts to Counter Human and Drug
Trafficking [Reissued with Revisions Feb. 7, 2022], GAO-22-105462, Published: Dec. 8, 2021, Publicly Released: Jan. 10, 2022,
available at https://www.gao.gov/products/gao-22-105462 (last visited Dec. 1, 2025).
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5
F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
HB 505 2026
1 A bill to be entitled
2 An act relating to virtual currency kiosks; creating
3 s. 560.215, F.S.; defining terms; requiring an owner
4 or operator of a virtual currency kiosk to ensure that
5 a specified disclosure is displayed before a customer
6 initiates a virtual currency kiosk transaction;
7 prohibiting an owner or operator of a virtual currency
8 kiosk from permitting new and existing customers from
9 transacting more than a specified amount per calendar
10 day; requiring an owner or operator of a virtual
11 currency kiosk to provide a customer with a specified
12 electronic receipt upon completion of a virtual
13 currency transaction; requiring an owner or operator
14 of a virtual currency kiosk to issue a full refund
15 under certain circumstances; authorizing the Financial
16 Services Commission to adopt rules; providing an
17 effective date.
18
19 Be It Enacted by the Legislature of the State of Florida:
20
21 Section 1. Section 560.215, Florida Statutes, is created
22 to read:
23 560.215 Requirements for virtual currency kiosks.—
24 (1) For the purpose of this section, the term:
25 (a) "Blockchain" means a mathematically secured,
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HB 505 2026
26 chronological, decentralized, distributed, and digital ledger or
27 database that consists of records of transactions that cannot be
28 altered retroactively.
29 (b) "Existing customer" means a customer who has
30 transacted with the owner or operator of a virtual currency
31 kiosk for 7 or more days.
32 (c) "New customer" means a customer who has transacted
33 with the owner or operator of a virtual currency kiosk for fewer
34 than 7 days.
35 (d) "Transaction hash" means a unique identifier
36 consisting of a string of characters which provides a verifiable
37 record that a transaction has been confirmed and added to the
38 blockchain.
39 (e) "Virtual currency kiosk" means an electronic terminal
40 that acts as a mechanical agent of the owner or operator,
41 enabling the owner or operator to facilitate the exchange of
42 virtual currency for fiat currency or other virtual currency on
43 behalf of a customer.
44 (f) "Virtual currency kiosk transaction" means the process
45 in which a customer uses a virtual currency kiosk to exchange
46 virtual currency for fiat currency or other virtual currency. A
47 transaction begins at the point at which the customer is able to
48 initiate a transaction after the customer is given the option to
49 select the type of transaction or account and does not include
50 any of the screens that display the required terms and
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51 conditions, disclaimers, or attestations.
52 (g) "Wallet" means hardware or software that enables
53 customers to store and use virtual currency.
54 (2) Before a customer may initiate a virtual currency
55 kiosk transaction, the owner or operator of the virtual currency
56 kiosk must ensure that the virtual currency kiosk clearly and
57 conspicuously displays the following disclosure on the screen:
58
59 WARNING: CONSUMER FRAUD OFTEN STARTS WITH CONTACT FROM
60 A STRANGER. IF YOU HAVE BEEN DIRECTED TO THIS MACHINE
61 BY SOMEONE CLAIMING TO BE A GOVERNMENT AGENT, BILL
62 COLLECTOR, LAW ENFORCEMENT OFFICER, OR ANYONE YOU DO
63 NOT KNOW PERSONALLY, STOP THIS TRANSACTION IMMEDIATELY
64 AND CONTACT YOUR FINANCIAL ADVISOR OR LOCAL LAW
65 ENFORCEMENT.
66
67 (3) The owner or operator of a virtual currency kiosk may
68 not permit a new customer to transact more than $2,000 per
69 calendar day, whether through a single transaction or multiple
70 transactions. The owner or operator of a virtual currency kiosk
71 may not permit an existing customer to transact more than
72 $10,500 per calendar day, whether through a single transaction
73 or multiple transactions.
74 (4) Upon completion of a virtual currency transaction, the
75 owner or operator of a virtual currency kiosk must provide the
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HB 505 2026
76 customer with an electronic receipt that includes all of the
77 following:
78 (a) The name and contact information of the owner or
79 operator, including a toll-free telephone number.
80 (b) The date, time, value, and type of the transaction.
81 (c) The transaction hash and each wallet used.
82 (d) The total fee charged.
83 (e) The exchange rate, if applicable.
84 (f) A statement of the owner's or operator's liability, if
85 any, for nondelivery or delayed delivery of the currency.
86 (g) The refund policy of the owner or operator.
87 (5) The owner or operator of a virtual currency kiosk must
88 issue a full refund within 72 hours to a customer for the
89 customer's first virtual currency transaction if all of the
90 following conditions are met:
91 (a) The customer transferred virtual currency to a wallet
92 or exchange located outside the United States.
93 (b) Within 60 days, the customer contacts both the owner
94 or operator of the virtual currency kiosk and a law enforcement
95 or governmental agency regarding the fraudulent nature of the
96 transaction.
97 (c) The customer provides proof of fraud, such as a police
98 report or a notarized affidavit.
99 (6) The commission may adopt rules to administer this
100 section.
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101 Section 2. This act shall take effect January 1, 2027.
102
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HB 527
FLORIDA HOUSE OF REPRESENTATIVES
BILL ANALYSIS
This bill analysis was prepared by nonpartisan committee staff and does not constitute an official statement of legislative intent.
BILL #: HB 527 COMPANION BILL: SB 202 (Bradley)
TITLE: Mandatory Human Reviews of Insurance Claim LINKED BILLS: None
Denials RELATED BILLS: None
SPONSOR(S): Cassel
Committee References
Insurance & Banking Commerce
SUMMARY
Effect of the Bill:
The bill establishes a statutory framework governing the use of artificial intelligence (AI) in claims handling.
Specifically, the bill prohibits insurers from denying or adjusting a claim based solely on the output of an AI system,
algorithm, or machine learning system. Instead, the bill requires a qualified human professional to make all denial
and adjustment decisions after analyzing the claim independently of any AI system, machine learning system, or
algorithm. The bill also mandates detailed recordkeeping, certain disclosures in denial letters, and updates to
claims-handling manuals for insurers who use AI as part of their claims-handling process.
Fiscal or Economic Impact:
There is an indeterminate fiscal impact on the private sector.
JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
ANALYSIS
EFFECT OF THE BILL:
The bill regulates the use of artificial intelligence systems1, machine learning systems2, and algorithms3 in
insurance claims handling. (Section 1). The bill prohibits the denial or adjustment of a claim based solely on these
systems. (Section 1). The bill requires that an individual with authority under the Florida Insurance Code to adjust
or deny a claim must be the person who makes decisions regarding the adjustment or denial of a claim. The bill
requires this individual, called a “qualified human professional,” to:
analyze the claim independently of any AI system, machine learning system, or algorithm;
review the accuracy of any output produced by an AI system, machine learning system, or algorithm; and
review the claim decisions made by other qualified human professionals. (Section 1).
The bill also requires insurers to maintain detailed records of claim denials, including:
the name and title of the qualified human professional responsible for the decision;
the date and time of the decision and any associated reviews of the claim adjustment; and
documentation of the basis for denial including any information provided by any AI system, machine
learning system, or algorithm. (Section 1).
1 The bill defines “artificial intelligence system” as a machine-based system that may have varying levels of autonomy and that
can, for a given set of objectives, generate outputs, such as predictions, recommendations, or content, influencing decisions
made in real or virtual environments.
2 The bill defines “machine learning system” as an artificial intelligence system that has the ability to learn from provided data
without being explicitly programmed.
3 The bill defines “algorithm” as a clearly specified mathematical process for computation which uses rules designed to give
prescribed results.
STORAGE NAME: h0527.IBS
DATE: 12/2/2025
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HB 527
Additionally, the bill requires insurers to include in their denial letters to policyholders the identity of the qualified
human professional, as well as an affirmation that an AI system, machine learning system, or algorithm was not the
sole basis for the denial. (Section 1).
Insurers who use AI systems, machine learning systems, or algorithms as part of their claims handling process
must update their claims handling manuals with details about how these systems are used by the insurer and how
those processes comply with the bill’s requirements. (Section 1).
The bill grants the Office of Insurance Regulation (OIR) the authority to carry out market conduct examinations
and investigations, or use any methods it deems necessary to verify compliance with the bill. (Section 1).
The bill provides an effective date of July 1, 2026. (Section 2).
RULEMAKING:
The bill grants rulemaking authority to the Financial Services Commission to implement the statutory framework
regulating the use of artificial intelligence in claims handling by insurers created by this bill.
Lawmaking is a legislative power; however, the Legislature may delegate a portion of such power to executive
branch agencies to create rules that have the force of law. To exercise this delegated power, an agency must
have a grant of rulemaking authority and a law to implement.
FISCAL OR ECONOMIC IMPACT:
PRIVATE SECTOR:
Indeterminate fiscal impact. Insurance companies that use AI systems, machine learning systems, or algorithms
may incur fiscal costs in order to comply with the bill.
RELEVANT INFORMATION
SUBJECT OVERVIEW:
Use of Artificial Intelligence Systems, Machine Learning Systems, and Algorithms by Insurers
Artificial intelligence is the development of computer systems to perform tasks that normally require human
intelligence, such as learning and decision-making.4 It enables computer systems to receive information that is
either provided to them by others or gathered by them, which they can then process and respond to in some
meaningful way. To a certain extent, AI systems can adjust their behavior by analyzing the results of prior actions
and operating without direct human control.5
The use of AI is becoming more prevalent across all industries, and major companies like IBM, Apple, Google, and
Amazon are using this technology internally and in their customer-facing products and services.6 AI technologies
are increasingly being used in certain insurance operations, such as underwriting, customer service, marketing,
fraud detection, and claims handling.7 A survey conducted by the National Association of Insurance Commissioners
(NAIC) found that out of 193 auto insurers surveyed, 88% reported either using or having plans to use AI or
4 National Conference of State Legislatures (NCSL), Artificial Intelligence 2025 Legislation, July 10, 2025,
https://www.ncsl.org/technology-and-communication/artificial-intelligence-2025-legislation (last visited Dec. 1, 2025).
5 European Parliament, What is artificial intelligence and how is it used?, E.U. News, Jun. 20, 2023,
https://www.europarl.europa.eu/topics/en/article/20200827STO85804/what-is-artificial-intelligence-and-how-is-it-used
(last visited Dec. 1, 2025).
6 National Association of Insurance Commissioners (NAIC), Artificial Intelligence, Jan. 17, 2025,
http://content.naic.org/insurance-topics/artificial-intelligence (last visited Dec. 1, 2025).
7 Id.
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machine learning systems.8 Similarly, out of 194 home insurers who responded to the NAIC survey, 70% of
insurers either use or plan to use these systems.9 The property and casualty insurers who were surveyed reported
using AI in claims handling to analyze accident images, to estimate claim settlement values, and to detect fraud.10
Florida Insurance Code
The Florida Insurance Code11 provides the regulatory framework for admitted insurers in the state. Currently, the
Florida Insurance Code does not regulate the use of artificial intelligence by insurers. However, insurers are bound
by certain requirements relating to claims handling. For example, property insurers are required to develop a
claims-handling manual that provides guidelines for processing claims that comply with all the requirements of the
Florida Insurance Code, and it grants OIR the authority to request a copy of this manual.12
Office of Financial Regulation
The Office of Insurance Regulation (OIR) regulates all activities relating to insurers and other risk bearing entities,
including licensing, rates, policy forms, marked conduct, claims, issuance of certificates of authority, solvency,
viatical settlements, premium financing, and administrative supervision.13 The OIR is responsible for examining the
affairs, transactions, accounts, records, and assets of each authorized insurer in the state.14 As part of that process,
insurers must make available all records relating to the subject of the examination.15 The OIR is also authorized to
carry out market conduct examinations to determine compliance with the Florida Insurance Code.16
Financial Services Commission
The Financial Services Commission is composed of the Governor, the Chief Financial Officer, the Attorney General,
and the Commissioner of Agriculture and it serves as agency head of the OIR for purposes of rulemaking.17 The
Financial Services Commission encompasses two offices: the Office of Insurance Regulation (responsible for
insurers and risk bearing entities) and the Office of Financial Regulation (responsible for the regulation of banks,
credit unions, other financial institutions, finance companies, and the securities industry).18
BILL HISTORY
STAFF
DIRECTOR/ ANALYSIS
COMMITTEE REFERENCE ACTION DATE POLICY CHIEF PREPARED BY
Insurance & Banking Brackett Miguez
Subcommittee
Commerce Committee
8 Id.
9 Id.
10 Id.
11 See s. 624.01, F.S.
12 S. 627.4108, F.S.
13 S. 20.121(3)(a), F.S.
14 S. 624.316(1)(a), F.S.
15 S. 624.318(2), F.S.
16 S. 624.3161, F.S.
17 S. 20.121(3), F.S.
18 Id.
JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
3
F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
HB 527 2026
1 A bill to be entitled
2 An act relating to mandatory human reviews of
3 insurance claim denials; creating s. 627.4263, F.S.;
4 defining terms; requiring that insurers' decisions to
5 deny a claim or any portion of a claim be made by
6 qualified human professionals; specifying the duties
7 of qualified human professionals; requiring an insurer
8 to maintain certain records; prohibiting the use of
9 algorithms, artificial intelligence, or machine
10 learning systems as the sole basis for determining
11 whether to adjust or deny a claim; requiring insurers
12 to include certain information in denial
13 communications to claimants; requiring that certain
14 insurers detail certain information in their claims-
15 handling manual; authorizing the Office of Insurance
16 Regulation to conduct market conduct examinations and
17 investigations under certain circumstances;
18 authorizing the Financial Services Commission to adopt
19 rules; providing an effective date.
20
21 Be It Enacted by the Legislature of the State of Florida:
22
23 Section 1. Section 627.4263, Florida Statutes, is created
24 to read:
25 627.4263 Mandatory human reviews of claim denials.—
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
HB 527 2026
26 (1) As used in this section, the term:
27 (a) "Algorithm" means a clearly specified mathematical
28 process for computation which uses rules designed to give
29 prescribed results.
30 (b) "Artificial intelligence system" means a machine-based
31 system that may have varying levels of autonomy and that can,
32 for a given set of objectives, generate outputs, such as
33 predictions, recommendations, or content, influencing decisions
34 made in real or virtual environments.
35 (c) "Machine learning system" means an artificial
36 intelligence system that has the ability to learn from provided
37 data without being explicitly programmed.
38 (d) "Qualified human professional" means an individual
39 who, under the Florida Insurance Code, has the authority to
40 adjust or deny a claim or a portion of a claim and may exercise
41 such authority over a particular claim.
42 (2) An insurer's decision to deny a claim or any portion
43 of a claim must be made by a qualified human professional.
44 (3) A qualified human professional shall, before
45 determining whether to adjust or deny a claim or a portion of a
46 claim, do all of the following:
47 (a) Analyze the facts of the claim and the terms of the
48 insurance policy independently of any artificial intelligence
49 system, machine learning system, or algorithm.
50 (b) Review the accuracy of any output generated by such a
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
HB 527 2026
51 system or algorithm.
52 (c) Conduct any review of a claim adjustment or claim
53 decision that was made by another qualified human professional.
54 (4) An insurer shall maintain detailed records of the
55 actions of qualified human professionals who are required to
56 perform the actions under subsection (3), including:
57 (a) The name and title of the qualified human professional
58 who made the decision to deny a claim or a portion of a claim
59 and of any qualified human professional who reviewed a claim
60 adjustment or claim decision.
61 (b) The date and time of the claim decision and of any
62 review of the claim adjustment.
63 (c) Documentation of the basis for the denial of the claim
64 or a portion of the claim, including any information provided by
65 an algorithm, an artificial intelligence system, or a machine
66 learning system.
67 (5) An algorithm, an artificial intelligence system, or a
68 machine learning system may not serve as the sole basis for
69 determining whether to adjust or deny a claim.
70 (6) In all denial communications to a claimant, an insurer
71 shall:
72 (a) Clearly identify the qualified human professional who
73 made the decision to deny the claim or a portion of the claim;
74 and
75 (b) Include a statement affirming that an algorithm, an
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HB 527 2026
76 artificial intelligence system, or a machine learning system did
77 not serve as the sole basis for determining whether to deny the
78 claim or a portion of the claim.
79 (7) An insurer that uses an algorithm, an artificial
80 intelligence system, or a machine learning system as part of its
81 claims-handling process shall detail in its claims-handling
82 manual the manner in which such systems are to be used and the
83 manner in which the insurer complies with this section.
84 (8) The office may conduct market conduct examinations and
85 investigations or use any method it deems necessary to verify
86 compliance with this section.
87 (9) The commission may adopt rules to implement this
88 section.
89 Section 2. This act shall take effect July 1, 2026.
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hb527-00
INSURANCE & BANKING SUBCOMMITTEE
HB 527 by Rep. Cassel
Mandatory Human Review of Insurance Claim Denials
AMENDMENT SUMMARY
December 9, 2025
Amendment by Rep. Cassel (strike-all):
• Expands the scope of the bill to include workers’ compensation and health maintenance
organizations (HMOs).
• Explicitly allows insurers to use algorithms, artificial intelligence systems, or machine
learning systems to assist in claims handling, including the generation of
recommendations to approve or deny a claim.
• Clarifies that the qualified human professional is only required to review denials, partial
denials, and claims where the payment is reduced.
• Creates penalties for workers’ compensation carriers who violate the bill’s requirements.
• Provides that insurers have to provide the unique identifier of the qualified human
professional to the policyholder instead of the professional’s name.
COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
COMMITTEE/SUBCOMMITTEE ACTION
ADOPTED (Y/N)
ADOPTED AS AMENDED (Y/N)
ADOPTED W/O OBJECTION (Y/N)
FAILED TO ADOPT (Y/N)
WITHDRAWN (Y/N)
OTHER
1 Committee/Subcommittee hearing bill: Insurance & Banking
2 Subcommittee
3 Representative Cassel offered the following:
4
5 Amendment (with title amendment)
6 Remove everything after the enacting clause and insert:
7 Section 1. Section 440.131, Florida Statutes, is
8 created to read:
9 440.131 Mandatory human reviews of claim denials.—
10 (1) As used in this section, the term:
11 (a) "Algorithm" means a clearly specified mathematical
12 process for computation which uses rules designed to give
13 prescribed results.
14 (b) "Artificial intelligence system" means a machine-based
15 system that may have varying levels of autonomy and that can,
16 for a given set of objectives, generate outputs, such as
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
17 predictions, recommendations, or content, influencing decisions
18 made in real or virtual environments.
19 (c) "Machine learning system" means an artificial
20 intelligence system that has the ability to learn from provided
21 data without being explicitly programmed.
22 (d) "Qualified human professional" means an individual
23 who, under the Florida Insurance Code, has the authority to
24 adjust or deny a claim or a portion of a claim and may exercise
25 such authority over a particular claim.
26 (2) A carrier may use an algorithm, artificial intelligence
27 system, or machine learning system to assist in processing
28 claims, including generating recommendations to approve or deny
29 a claim or a portion of a claim, in accordance with this
30 section.
31 (3) A decision to reduce a payment of a claim, deny a
32 claim, or deny a portion of a claim or to reduce a claim payment
33 may not be made solely on the basis of an algorithm, artificial
34 intelligence system, or machine learning system. A carrier’s
35 decision to deny a claim or any portion of a claim or a payment
36 claim reduction must be made by a qualified human professional.
37 (4) If an algorithm, artificial intelligence system, or
38 machine learning system assists in processing a claim, the
39 qualified human professional must do the following before
40 reducing a claim payment or denying the claim or a portion of
41 the claim:
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
42 (a) Analyze the facts of the claim and the terms of the
43 insurance policy independently of any artificial intelligence
44 system, machine learning system, or algorithm.
45 (b) Review the accuracy of any output generated by such a
46 system or algorithm.
47 (c) Determine that the claim or portion of the claim is not
48 payable under the terms of the insurance policy and should be
49 denied or that the claim payment should be reduced.
50 (5) A carrier shall maintain detailed records of the
51 actions of qualified human professionals who are required to
52 perform the actions under subsection (3), including:
53 (a) The name, title, business address, and the unique
54 identifier associated with the name of the qualified human
55 professional who made the decision to reduce the claim payment,
56 deny the claim, or deny a portion of the claim.
57 (b) The date and time of the qualified human
58 professional’s decision.
59 (c) Documentation of the basis for the reduction of the
60 claim payment, denial of the claim, or denial of a portion of
61 the claim, including any information provided by an algorithm,
62 an artificial intelligence system, or a machine learning system.
63 (6) In all written denial communications to an injured
64 employee, a carrier shall include:
65 (a) An email address, telephone number, business address,
66 and unique identifier, in lieu of the name of the qualified
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
67 human professional who made the decision to reduce the claim
68 payment, deny the claim, or deny a portion of the claim; and
69 (b) A written statement affirming that an algorithm, an
70 artificial intelligence system, or a machine learning system did
71 not serve as the sole basis for determining whether to reduce
72 the claim payment, deny the claim, or deny a portion of the
73 claim.
74 (7) A carrier that uses an algorithm, an artificial
75 intelligence system, or a machine learning system as part of its
76 claims-handling process shall detail in its claims-handling
77 manual the manner in which such systems are to be used and the
78 manner in which the carrier complies with this section.
79 (8) The department may conduct examinations and
80 investigations it deems necessary to verify compliance with this
81 section.
82 (9) The department may adopt rules to implement this
83 section.
84 (10) Failure to comply with this section shall be
85 considered a violation of this chapter and is subject to
86 penalties as provided for in s. 440.525.
87 Section 2. Section 627.4263, Florida Statutes, is created
88 to read:
89 627.4263. Mandatory human reviews of claim denials.—
90 (1) As used in this section, the term:
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
91 (a) "Algorithm" means a clearly specified mathematical
92 process for computation which uses rules designed to give
93 prescribed results.
94 (b) "Artificial intelligence system" means a machine-based
95 system that may have varying levels of autonomy and that can,
96 for a given set of objectives, generate outputs, such as
97 predictions, recommendations, or content, influencing decisions
98 made in real or virtual environments.
99 (c) "Machine learning system" means an artificial
100 intelligence system that has the ability to learn from provided
101 data without being explicitly programmed.
102 (d) "Qualified human professional" means an individual
103 who, under the Florida Insurance Code, has the authority to
104 adjust or deny a claim or a portion of a claim and may exercise
105 such authority over a particular claim.
106 (2) An insurer may use an algorithm, artificial
107 intelligence system, or machine learning system to assist in
108 processing claims, including generating recommendations to
109 approve or deny a claim or a portion of a claim, in accordance
110 with this section.
111 (3) A decision to reduce a payment of a claim, deny a
112 claim, or deny a portion of a claim or to reduce a claim payment
113 may not be made solely on the basis of an algorithm, artificial
114 intelligence system, or machine learning system. An insurer’s
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
115 decision to deny a claim or any portion of a claim or a payment
116 claim reduction must be made by a qualified human professional.
117 (4) If an algorithm, artificial intelligence system, or
118 machine learning system assists in processing a claim, the
119 qualified human professional must do the following before
120 reducing a claim payment, denying the claim or a portion of the
121 claim:
122 (a) Analyze the facts of the claim and the terms of the
123 insurance policy independently of any artificial intelligence
124 system, machine learning system, or algorithm.
125 (b) Review the accuracy of any output generated by such a
126 system or algorithm.
127 (c) Determine that the claim or portion of the claim is not
128 payable under the terms of the insurance policy and should be
129 denied or that the claim payment should be reduced.
130 (5) An insurer shall maintain detailed records of the
131 actions of qualified human professionals who are required to
132 perform the actions under subsection (3), including:
133 (a) The name, title, business address, and the unique
134 identifier associated with the name of the qualified human
135 professional who made the decision to reduce the claim payment,
136 deny the claim, or deny a portion of the claim.
137 (b) The date and time of the qualified human
138 professional’s decision.
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
139 (c) Documentation of the basis for the reduction of the
140 claim payment, denial of the claim, or denial of a portion of
141 the claim, including any information provided by an algorithm,
142 an artificial intelligence system, or a machine learning system.
143 (6) In all written denial communications to an insured, an
144 insurer shall include:
145 (a) An email address, telephone number, business address,
146 and unique identifier, in lieu of the name of the qualified
147 human professional who made the decision to reduce the claim
148 payment, deny the claim, or deny a portion of the claim; and
149 (b) A written statement affirming that an algorithm, an
150 artificial intelligence system, or a machine learning system did
151 not serve as the sole basis for determining whether to reduce
152 the claim payment, deny the claim, or deny a portion of the
153 claim.
154 (7) An insurer that uses an algorithm, an artificial
155 intelligence system, or a machine learning system as part of its
156 claims-handling process shall detail in its claims-handling
157 manual the manner in which such systems are to be used and the
158 manner in which the insurer complies with this section.
159 (8) The office may conduct market conduct examinations and
160 investigations it deems necessary to verify compliance with this
161 section.
162 (9) The commission may adopt rules to implement this
163 section.
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
164 Section 3. Section 641.31090, Florida Statutes, is created
165 to read:
166 641.31090 Mandatory human reviews of claim denials.—
167 (1) As used in this section, the term:
168 (a) "Algorithm" means a clearly specified mathematical
169 process for computation which uses rules designed to give
170 prescribed results.
171 (b) "Artificial intelligence system" means a machine-based
172 system that may have varying levels of autonomy and that can,
173 for a given set of objectives, generate outputs, such as
174 predictions, recommendations, or content, influencing decisions
175 made in real or virtual environments.
176 (c) "Machine learning system" means an artificial
177 intelligence system that has the ability to learn from provided
178 data without being explicitly programmed.
179 (d) "Qualified human professional" means an individual
180 who, under the Florida Insurance Code, has the authority to
181 adjust or deny a claim or a portion of a claim and may exercise
182 such authority over a particular claim.
183 (2) A health maintenance organization may use an algorithm,
184 artificial intelligence system, or machine learning system to
185 assist in processing claims, including generating
186 recommendations to approve or deny a claim or a portion of a
187 claim, in accordance with this section.
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
188 (3) A decision to reduce a payment of a claim, deny a
189 claim, or deny a portion of a claim or to reduce a claim payment
190 may not be made solely on the basis of an algorithm, artificial
191 intelligence system, or machine learning system. A health
192 maintenance organization’s decision to deny a claim or any
193 portion of a claim or a payment claim reduction must be made by
194 a qualified human professional.
195 (4) If an algorithm, artificial intelligence system, or
196 machine learning system assists in processing a claim, the
197 qualified human professional must do the following before
198 reducing a claim payment, denying the claim or a portion of the
199 claim:
200 (a) Analyze the facts of the claim and the terms of the
201 contract independently of any artificial intelligence system,
202 machine learning system, or algorithm.
203 (b) Review the accuracy of any output generated by such a
204 system or algorithm.
205 (c) Determine that the claim or portion of the claim is not
206 payable under the terms of the insurance policy and should be
207 denied or that the claim payment should be reduced.
208 (5) A health maintenance organization shall maintain
209 detailed records of the actions of qualified human professionals
210 who are required to perform the actions under subsection (3),
211 including:
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Bill No. HB 527 (2026)
Amendment No.
212 (a) The name, title, business address, and the unique
213 identifier associated with the name of the qualified human
214 professional who made the decision to reduce the claim payment,
215 deny the claim, or deny a portion of the claim.
216 (b) The date and time of the qualified human
217 professional’s decision.
218 (c) Documentation of the basis for the reduction of the
219 claim payment, denial of the claim, or denial of a portion of
220 the claim, including any information provided by an algorithm,
221 an artificial intelligence system, or a machine learning system.
222 (6) In all written denial communications to a subscriber,
223 a health maintenance organization shall include:
224 (a) An email address, telephone number, business address,
225 and unique identifier, in lieu of the name of the qualified
226 human professional who made the decision to reduce the claim
227 payment, deny the claim, or deny a portion of the claim; and
228 (b) A written statement affirming that an algorithm, an
229 artificial intelligence system, or a machine learning system did
230 not serve as the sole basis for determining whether to reduce
231 the claim payment, deny the claim, or deny a portion of the
232 claim.
233 (7) A health maintenance organization that uses an
234 algorithm, an artificial intelligence system, or a machine
235 learning system as part of its claims-handling process shall
236 detail in its claims-handling manual the manner in which such
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
237 systems are to be used and the manner in which the health
238 maintenance organization complies with this section.
239 (8) The office may conduct market conduct examinations and
240 investigations or use any method it deems necessary to verify
241 compliance with this section.
242 (9) The commission may adopt rules to implement this
243 section.
244 Section 4. This act shall take effect July 1, 2026.
245
246 -----------------------------------------------------
247 T I T L E A M E N D M E N T
248 Remove everything before the enacting clause and insert:
249 An act relating to mandatory human reviews of
250 insurance claim denials; creating s. 440.131, F.S.;
251 defining terms; allowing workers’ compensation
252 carriers to use algorithms, artificial intelligence
253 systems, and machine learning systems to assist in
254 processing claims; prohibiting the use of algorithms,
255 artificial intelligence, or machine learning systems
256 as the sole basis for determining whether to reduce a
257 claim payment or deny a claim; requiring that
258 carriers’ decisions to deny a claim or reduce a claim
259 be made by qualified human professionals; specifying
260 the duties of qualified human professionals; requiring
261 a carrier to maintain certain records; requiring
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
262 carriers to include certain information in denial
263 communications to claimants; requiring that certain
264 carriers detail certain information in their claims-
265 handling manual; authorizing the Department of
266 Financial Services to adopt rules; providing
267 penalties; creating s. 627.4263, F.S.; defining terms;
268 allowing insurers to use algorithms, artificial
269 intelligence systems, and machine learning systems to
270 assist in processing claims; prohibiting the use of
271 algorithms, artificial intelligence, or machine
272 learning systems as the sole basis for determining
273 whether to reduce a claim payment or deny a claim;
274 requiring that insurers’ decisions to deny a claim or
275 reduce a claim be made by qualified human
276 professionals; specifying the duties of qualified
277 human professionals; requiring an insurer to maintain
278 certain records; requiring insurers to include certain
279 information in denial communications to claimants;
280 requiring that certain insurers detail certain
281 information in their claims-handling manual;
282 authorizing the Office of Insurance Regulation to
283 conduct market conduct examinations and investigations
284 under certain circumstances; authorizing the Financial
285 Services Commission to adopt rules; creating s.
286 641.31090, F.S.; defining terms; allowing health
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COMMITTEE/SUBCOMMITTEE AMENDMENT
Bill No. HB 527 (2026)
Amendment No.
287 maintenance organizations to use algorithms,
288 artificial intelligence systems, and machine learning
289 systems to assist in processing claims; prohibiting
290 the use of algorithms, artificial intelligence, or
291 machine learning systems as the sole basis for
292 determining whether to reduce a claim payment or deny
293 a claim; requiring that health maintenance
294 organizations’ decisions to deny a claim or reduce a
295 claim be made by qualified human professionals;
296 specifying the duties of qualified human
297 professionals; requiring a health maintenance
298 organization to maintain certain records; requiring
299 health maintenance organizations to include certain
300 information in denial communications to claimants;
301 requiring that certain health maintenance
302 organizations detail certain information in their
303 claims-handling manual; authorizing the Office of
304 Insurance Regulation to conduct market conduct
305 examinations and investigations under certain
306 circumstances; authorizing the Financial Services
307 Commission to adopt rules; providing an effective
308 date.
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