When Texas’ new clinical AI disclosure law took effect Jan. 1, two of the state’s largest health systems had quietly reached the same conclusion: Existing consent forms provided a practical path to compliance.
Lawmakers in 47 states introduced more than 250 bills regulating AI in healthcare in 2025, with 34 signed into law across 21 states. Texas is at the center of that shift.
The Texas Responsible Artificial Intelligence Governance Act is one of the most far-reaching clinical AI laws enacted to date. Under TRAIGA, healthcare providers must give patients or their personal representatives conspicuous written disclosure whenever an AI system is used in diagnosis or treatment. That disclosure must occur before or at the time of the clinical interaction, with a narrow exception for emergencies.
The law took effect Jan. 1. Two Texas health system leaders shared with Becker’s how their organizations built out compliance in practice.
Serina Rivela, senior vice president and chief legal officer at San Antonio-based University Health, said the organization took a broad, patient-centered approach to defining what triggers a disclosure.
“Our standard is based on what a reasonable patient would consider to be AI-generated or AI-assisted in the context of diagnosis or treatment decisions,” she said. “This framework is incorporated into our general consent process to ensure transparency without creating unnecessary complexity in clinical workflows.”
Disclosures are delivered in two ways: verbally when AI meaningfully informs a care decision and through standardized language embedded in general consent forms. Ms. Rivela said patient response has been largely neutral, with limited direct feedback or concerns raised.
“This suggests that integrating disclosures into existing consent processes has helped normalize the use of AI while maintaining patient trust,” she said.
At Houston Methodist, Jordan Dale, MD, chief medical information officer and chief health AI officer, said the health system focused its disclosure framework the same way.
“We’ve taken a careful, patient-centered approach by considering whether the use is external-facing, whether a patient would naturally recognize AI involvement and how closely it is connected to care delivery or patient engagement,” Dr. Dale said.
The health system also built its disclosures into existing workflows rather than relying on standalone notices. The effort included enhancing Houston Methodist’s consent for treatment to reflect AI use. For specific interactions, such as AI-enabled calls or ambient listening, the health system focuses on being transparent at or before the interaction.
“We’ve approached implementation with the understanding that regulatory guidelines are still evolving, so it’s important for our approach to remain flexible and thoughtful as things continue to take shape,” Dr. Dale said. “At every step, our focus has been on helping patients feel informed, comfortable and confident, with the understanding that any use of AI is guided by a strong commitment to protecting patient privacy, safety and trust.”
While Houston Methodist has not observed widespread or consistent patient response directly tied to the disclosures, the organization has received thoughtful questions, particularly around ambient listening and AI-assisted documentation.
“In some cases, patients have asked thoughtful questions about how their information may be used, giving us an opportunity to provide additional context and reassurance,” Dr. Dale said. “We explain that data used in these systems is deidentified and part of broader, aggregated processes that support care delivery and improvement.”
Looking ahead, Dr. Dale said the health system is continuing to listen closely and learn from these interactions, with the goal of reinforcing transparency, maintaining trust and ensuring that patient privacy and safety “remain at the center of everything we do.”
Texas is not alone. According to a Dec. 16 Manatt Health analysis, states are expected to remain the primary regulators of healthcare AI in 2026. At least four states have enacted laws that directly govern how health systems must disclose or limit AI use in clinical care, and dozens more bills are advancing in 2026.
At the Becker's 11th Annual IT + Revenue Cycle Conference: The Future of AI & Digital Health, taking place September 14–17 in Chicago, healthcare executives and digital leaders from across the country will come together to explore how AI, interoperability, cybersecurity, and revenue cycle innovation are transforming care delivery, strengthening financial performance, and driving the next era of digital health. Apply for complimentary registration now.
