PHI to a model is now a HIPAA, CIPA, and ERISA event.

Tokto records every prompt, every model summary, every ambient-listening capture, and every vendor data flow against the patient, the plan, the clinician, and the authorization, ready for OIG, CMS, the state DOI, and the appellate panel.

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 claim, and HIPAA audit at once.

How it works

Tokto sits between the plan's AI tools and the patient record. Utilization-management co-pilots, ambient clinical scribes, prior-authorization triage models, and vendor APIs all flow through the system of record. Each output is attributable to the member, the plan, the clinician, and the disclosure language active that day.

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, the record is the same record. The CISO is no longer a witness reconstructing facts under deposition pressure.

What goes wrong without it

• An AI tool denies a post-acute care claim with no recorded clinical review. The class moves past motion to dismiss on ERISA.
• An ambient-listening scribe captures patient audio without consent and ships it to a third-party processor. 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, OIG inquiry.
• The plan is asked to produce algorithmic disclosure on a federal order. The model team and the legal team produce inconsistent answers.