NHeLP AHRQ Comments

Executive Summary

In these comments, NHeLP responds to a request for information from AHRQ regarding the use of clinical algorithms that have the potential to introduce racial/ethnic bias into healthcare delivery. Using our long history of litigation and advocacy on issues that involve the use of automated decision-making systems, including algorithms, in Medicaid we provided information on the importance of transparency around such systems and the need for robust due process protections around their use. Our comments also discussed sources of bias in health care algorithms and the importance of going beyond an examination of health care for racial bias, and extend that review to other factors given existing algorithmic bias regarding race, ethnicity, disability, age, sexual orientation, gender identity, and other factors. These comments also encourage focusing on the impact on individuals and recognizing that health care algorithms will likely be imperfect and biased, so the safety net for algorithmic decisions must not be.

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