Aipedia: Occupational health providers

AI-drafted occupational health management referral reports

Aipedia, by the Apex broking team · Last reviewed 2026-10-27

AI can draft an OH management referral report, but the clinician must make sure it is accurate, balanced and limited to what the employer needs. These reports shape decisions about a worker's job, so errors can draw complaints from the worker and claims from the employer.

Part of: AI in occupational health providers

In short

OH clinicians may use generative AI to turn assessment notes into management referral reports that answer an employer's questions on fitness for work, adjustments and likely return dates. GMC guidance para 7 requires such reports not to be false or misleading and to give a balanced opinion, and para 115 requires consent, disclosure of only relevant information and, usually, an offer to show the worker the report first. AI drafts may add unnecessary clinical detail and confident language. The clinician must edit every report as their own.

How OH teams use AI for referral reports

A management referral usually asks set questions: is the worker fit for their role, what adjustments would help, is a disability likely, and when might they return. Clinicians use AI tools to turn typed or transcribed assessment notes into a draft that answers each question, to standardise tone across a team, and to produce a plain English summary for the manager. Some OH software may offer this inside the case record. The time saving is real, but the tool has not met the worker and does not know what they agreed to share.

The duties that apply

The GMC's guidance on disclosing information for employment, insurance and similar purposes applies directly to occupational physicians:

Para 7: reports must not be false or misleading, should stay within your direct knowledge and must give a balanced opinion.
Para 115(a) and (b): the worker must understand the scope, purpose and likely consequences of the report, and you need or must see written consent.
Para 115(c): disclose only relevant factual information, usually not the whole record.
Para 115(d): usually offer to show the worker the report before it is sent.
Paras 10 to 12: correct factual errors and respect withdrawal of consent.

The ICO's workers' health guidance adds that managers usually need only fitness-for-work information, not diagnoses or detailed history. OH nurses are bound by NMC Code 5.1, 5.2 and 10.1 to 10.3, and HCPC registrants by standards 5.1, 5.2 and 10.1 to 10.3.

What can go wrong

Illustrative scenario: an OH nurse uses a generative AI tool to draft a report after a telephone assessment for anxiety. The draft includes a diagnosis, a reference to a past episode the worker mentioned in confidence, and a sentence stating the worker is "unlikely to sustain full duties". The nurse sends it without the worker seeing it. The worker complains to the NMC and the ICO, and the employer later relies on the pessimistic prognosis in a capability dismissal. Both the worker and the employer question the report.

Other possible problems include AI wording that sounds more certain than the clinician's view, answers to questions the employer did not ask, and stock adjustment lists copied between workers. Each one can turn a routine report into evidence in a tribunal or a complaint to the regulator.

How PI usually responds

A claim that a report was negligent is the core risk an OH professional indemnity policy is designed for, and using AI to draft it does not usually change that, subject to the policy terms. Points to check are whether the policy covers the OH company as well as each clinician, whether data protection claims for over-disclosure are covered or excluded, and any condition that a qualified person must review outputs. Clinicians must hold indemnity by statute, with no minimum limits set. NHS indemnity excludes OH work for employers. See does OH indemnity cover AI mistakes and data breach cover within PI.

Practical controls

Use only AI tools approved for health data, with a DPIA and supplier terms in place.
Draft from your own notes and remove anything the manager does not need.
Check every statement against the assessment; delete prognoses you did not form.
Answer only the questions asked, in your own words where opinion is involved.
Offer the worker the report before release and record their response and consent.
Keep a record of AI use in the case file.

How Apex helps

Apex arranges PI for occupational health providers and clinicians. A broker reviews your cover and how the policy treats reports drafted with AI, including any data protection exclusions; see OH professional indemnity.

Sources

Frequently asked

Can I use AI to write an OH report for an employer?

Yes, if you treat the output as a draft. GMC guidance requires reports not to be false or misleading and to give a balanced opinion, and you must disclose only relevant information. Check every line against your assessment and use a tool approved for health data.

Should the worker see an AI-drafted report first?

GMC para 115(d) says you should usually offer to show the report to the worker before it is sent. This is a useful check on AI errors, because the worker may spot a wrong fact or unnecessary detail before it reaches the employer.

Who might claim over a wrong referral report?

A worker may complain to the regulator or ICO, or claim over disclosure or an inaccurate opinion. An employer may claim if it relied on flawed advice in a dismissal or a failed adjustment. OH professional indemnity usually responds to negligent advice claims, subject to its terms.

Check your indemnity covers how you use AI

Tell us about your practice and the work you do. A broker will review how your current cover treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

Start an indemnity quote Request a callback

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.