AI claim denial is now a discoverable liability.

Tokto gives the health plan's General Counsel one record that ties every AI denial, every clinical review, every ambient capture, and every PHI flow to a member, a plan, and a clinician, ready for ERISA, HIPAA, CIPA, and state DOI scrutiny on the same evidence.

What you get with Tokto

• Every prompt tied to a member, a plan, a clinician, an authorization, and a denial code.
• A complete record for OIG, CMS, the state DOI, the ERISA plaintiff, the appellate panel, and the HIPAA auditor.
• Policy applied at the prompt: no AI denial without clinical review, no PHI to a vendor without contract.
• Defensibility under class certification, ERISA scrutiny, CIPA wiretap, and HIPAA audit at once.

How it works

Tokto governs the AI surface across the plan. Utilization-management co-pilots, ambient clinical scribes, prior-authorization triage models, and vendor APIs all flow through the system of record. Every output is attributable to the member, the plan, the clinician, the authorization, and the denial code, with the disclosure language active that day stamped on the record.

When the District of Minnesota orders algorithmic disclosure, when an ERISA appellate panel asks how a denial was clinically reviewed, when a state AG opens a CIPA wiretap inquiry on an ambient scribe, the record is the same record. The General Counsel works one defense theory across four courts.

What goes wrong without it

• An AI denial reaches a 90-percent reversal-on-appeal pattern with no per-member clinical-review record. Class certifies on the same theory as nH Predict.
• An ambient clinical scribe captures patient audio without consent. CIPA, CMIA, and Federal Wiretap Act all open.
• A vendor with PHI access has no current BAA, no audit trail, and no policy enforcement. HIPAA breach disclosure follows.
• A federal court orders algorithmic disclosure. The plan and its model vendor produce inconsistent answers in the same week.