Artificial Intelligence
The following is issued as interim guidance given the rapid pace of change in this area. We will keep it updated to ensure osteopaths feel as supported as possible. We welcome feedback from osteopaths, patients, education providers and other partners across the osteopathic profession. To share your views, please email standards@osteopathy.org.uk
Interim guidance on the use of Artificial Intelligence (AI) in osteopathic practice
- Why do osteopaths need guidance on AI?
- What is artificial intelligence?
- Accountability
- AI literacy
- Transparency and consent
- Patient safety and confidentiality
- Further resources on AI
Why do osteopaths need guidance on AI?
Although human interaction, touch and a holistic approach to the patient will continue to be the key foundations of osteopathic practice, we recognise that AI is becoming increasingly integrated into our daily lives and, in particular, into healthcare settings.
Therefore it is essential for osteopaths who are using, or intending to use, AI as part of their practice, to reflect on how the Osteopathic Practice Standards (OPS) are applied in this area for the benefit of osteopaths, patients and society.
This interim guidance on AI does not expand the remit of the existing OPS, but explains osteopaths’ responsibilities if using AI. As AI changes rapidly, we will continue to keep this guidance updated to ensure that osteopaths feel as supported as possible.
What is artificial intelligence?
Artificial intelligence refers to a type of computer science that enables machines and systems to perform tasks previously associated with human intelligence, such as learning and problem solving.
AI can be used in a range of ways that may be relevant to osteopaths, for example:
- transcribing patient notes, information or reflections
- translating information for patients
- for security, such as facial recognition rather than a pin which might be used to protect patient notes
- summarising research or case studies
- providing feedback to learners for continuing professional development (CPD)
- supporting reflection or assessments in the context of education and CPD
- as part of wearable technology, which patients may ask osteopaths to consider as part of their clinical picture
In wider health, AI is being used or considered for use in areas such as:
- diagnosis in patients
- preventative medicine
- gathering standard preliminary information from patients ahead of referrals (See this case study from the NHS on using an AI chatbot)
Below are key principles which have been drawn from the OPS that osteopaths should be considering if using AI in healthcare.
‘The standards set out the expectations of osteopaths as regulated healthcare professionals. Patients must be able to trust osteopaths with their health. To justify that trust osteopaths must meet the standards expected in the Osteopathic Practice Standards. Osteopaths are personally accountable for their professional practice and must always be prepared to justify their decisions and actions, explaining how they have exercised their professional judgement.’ (see p4 of the OPS)
Accountability
If osteopaths use artificial intelligence in their practice, they are responsible for its use in accordance with the OPS. This means osteopaths are responsible for complying with ethical, legal and competence standards and remain fully accountable for their clinical decision making – these responsibilities cannot be outsourced to AI, developers of AI or employers. When using AI technologies, osteopaths should always put patients at the centre of their decision making.
Depending on the type of AI tool used, osteopaths will need to consider carefully whether it has been approved for use by the appropriate regulators in the UK (for example, the Medicines and Healthcare Regulatory Products Agency for AI powered medical devices).
AI literacy
It is important that when using AI tools in their practice, osteopaths understand enough about how the AI tool operates to be able to use it safely and in line with the OPS. AI tools are developing at a rapid pace and if using this technology, we expect osteopaths to understand the risks and benefits of the technology, its limitations, and to keep their knowledge and skills up to date through CPD.
If osteopaths are using AI tools, we do not expect them to be technical experts; however, at the very least, osteopaths should be able to discuss with patients what any tool or system they are using does, any risks and benefits associated with it and what happens to their information.
AI tools and systems also have the potential to provide inaccurate or misleading responses and present these as facts. These are known as ‘hallucinations’. Osteopaths also need to be aware of potential bias in system outputs. If using AI it is important that osteopaths carefully consider the information they get from the system, remembering that the AI advice might not be suitable for all patients and all demographics particularly given the potential diversity of patients that osteopaths will treat.
Most relevant OPS standards:
B1: You must have and be able to apply sufficient and appropriate knowledge and skills to support your work as an osteopath.
B2: You must recognise and work within the limits of your training and competence.
B3: You must keep your professional knowledge and skills up to date.
D6: You must treat patients fairly and recognise diversity and individual values. You must comply with equality and anti-discrimination law.
Transparency and consent
If using AI tools, it is important that this is discussed with patients and explained to them in a way they can understand easily. Osteopaths should also be able to answer any simple questions patients have about the AI tool being used. The level of detail osteopaths will need to provide is dependent upon the risk to the patient and how and when AI is used. Being transparent is important to maintaining trust and patient confidence in the profession.
Osteopaths must also consider the level of patient consent required when using an AI tool. For example, if using transcription software, this would mean an osteopath including reference to this in their privacy notice.
Most relevant standards:
A1: You must listen to patients and respect their individuality, concerns and preferences. You must be polite and considerate with patients and treat them with dignity and courtesy.
A2: You must work in partnership with patients, adapting your communication approach to take into account their particular needs and supporting patients in expressing to you what is important to them.
A3: You must give patients the information they want or need to know in a way they can understand.
A4: You must receive valid consent for all aspects of examination and treatment and record this as appropriate.
D1: You must act with honesty and integrity in your professional practice.
Patient safety and confidentiality
Patient safety continues to be paramount regardless of whether an osteopath chooses to use any AI technology as part of their practice. If osteopaths identify any AI outputs that could put patients at risk of harm, they should know how to raise a concern with the provider of the tool or system they are using. Patients should also understand how they can raise a concern with their osteopath regarding how AI is being used in their practice.
When using AI tools, osteopaths must ensure patient confidentiality is maintained by continuing to comply with laws on data protection, such as the UK General Data Protection Regulation (GDPR). Some AI tools are provided free to the public and osteopaths must be aware that sharing confidential data with these tools would be likely to breach confidentiality.
Osteopaths will also need to maintain up to date privacy policies and meet requirements for registration with the Information Commissioners Office if not already registered. As with any technology used, osteopaths must consider how the tool is storing patient data and where the data is located. Osteopaths also need to understand whether patient data is being used to train the AI tool and what happens to any identifiable patient information. Osteopaths must ensure that they understand the terms of use and the privacy policy before using AI.
Osteopaths are also responsible for ensuring that any AI tool they use has adequate cyber security measures in place. This is to ensure that patient data is adequately protected.
Osteopaths will need to consider whether their insurers require any specific declaration about their use of AI as part of their clinical practice.
Most relevant standards:
C2: You must ensure that your patient records are comprehensive, accurate, legible and completed promptly.
C4: You must take action to keep patients from harm.
D4: You must have a policy in place to manage patient complaints and respond quickly and appropriately to any that arise
D5: You must respect your patients’ rights to privacy and confidentiality, and maintain and protect patient information effectively.
Further resources on AI
AI Digital and Regulations Service for the NHS
Artificial Intelligence -10 promising interventions in healthcare - NIHR, 2023
How to use AI and Personal Data appropriately and lawfully - ICO, 2022
Guidance on AI and data protection - ICO, 2023
NHS Change programme (2024) and the priorities of
- moving care from hospitals to communities
- making better use of technology
- focussing on preventing sickness, not just treating it as part of the development of the NHS plan
Horizon Scanning – Parliament (2024) - Artificial Intelligence ethics
Information Commissioners Office website - data protection FAQs
