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Utah Authorises Two Clinical AI Pilots Under State AI Sandbox, 2 October 2026

The Utah Office of Artificial Intelligence Policy and the Division of Professional Licensing signed two further AI sandbox agreements on 2 October 2026, covering Expect Fitness for pelvic floor physical therapy care plans and August AI for routine prescription refills. A third agreement, with Nolla Health for topical acne prescriptions, was signed on 22 September 2026 and runs from 5 October 2026 to 5 October 2027.

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The Utah Office of Artificial Intelligence Policy, with the Division of Professional Licensing as co-signatory, approved two further agreements under the state AI sandbox on 2 October 2026. One covers Expect Fitness for artificial intelligence generated pelvic floor physical therapy care plans, the other covers August AI for artificial intelligence authorised refills of existing non controlled prescriptions. Neither term had begun when the office published its register of authorised pilots. A third agreement, with Nolla Health for artificial intelligence issued topical acne prescriptions, was signed on 22 September 2026 and runs from 5 October 2026 to 5 October 2027.

The programme sits in Utah Code title 13, chapter 72. Section 13-72-301 establishes it, section 13-72-402 sets out what an applicant must demonstrate, and section 13-72-403 governs the term of an agreement and its extension. Section 13-72-401 carries the operating conditions, with subsection (6) imposing the audit duty and subsections (7) to (10) covering scope, termination, the absence of state endorsement and state liability. Section 13-72-201(3)(d) requires annual reporting. Relief is not granted at large: each agreement is a narrow, time limited, written change to how certain rules apply, and it runs only to the provisions named in that agreement's Schedule A.

For Expect Fitness and August AI, the Division of Professional Licensing will not enforce unlicensed and unprofessional conduct provisions or telehealth rules against the named activity at the oversight levels each agreement sets, and the relief reaches nothing else those companies offer. The August AI agreement does not permit the tool to write a new prescription, change a dose or substitute one medication for another. Digital health operators, supervising clinicians and their insurers should read the term dates together with Schedule A, because an agreement that has not started, or that has expired as the Dentacor and ElizaChat agreements have, carries no relief at all.

Master agreements signed with University of Utah Health on 10 September 2026 and with Intermountain Health in September 2026 authorise nothing on their own, and relief under them must be set out in individual addenda, with pilots running twelve months. The reach of this relief is visible in the expired ElizaChat agreement, which did not cover a claim by a student, a parent or an injured third party. Agreements stay subject to the audit duty in section 13-72-401(6) and to the term and extension rules in section 13-72-403.

Licentium advises digital health developers, clinician groups and investors on United States state level AI authorisation routes and the conditions attached to them. Work we undertake includes sandbox and regulatory mitigation agreement applications, scope drafting for Schedule A relief, licensing and telehealth exposure analysis, and audit and annual reporting compliance under Utah Code title 13, chapter 72.

Source: Utah Office of Artificial Intelligence Policy, Authorized AI Pilots, agreements of 22 September and 2 October 2026

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