How does this differ from a legal compliance review?
A legal review interprets the bulletin and your obligations. This audit translates those obligations into specific operational gaps, scored against what regulators are actually looking for in the NAIC AI Systems Evaluation Tool, and then sequences the fixes by severity and effort. Many of my clients run a legal review and this audit in parallel because they answer different questions.
Is this only for insurance carriers?
Insurance is the primary lane because the NAIC bulletin is the most concrete regulatory framework right now, but healthcare organizations face a parallel set of expectations under HHS, JCAHO, and FDA TEMPO. The audit is calibrated to the regulatory environment that applies to you, so a hospital system or digital health company gets the same scorecard structure tuned against their applicable frameworks.
What if our state has not adopted the NAIC bulletin yet?
The bulletin has been adopted in roughly 25 states as of early 2026, and the trend is one-way. Even in states that have not formally adopted it, examiners increasingly use the Evaluation Tool framework as a reference standard. Building toward it now is the lowest-risk posture, and the same controls satisfy most adjacent state-level guidance.
Will you talk to our regulators on our behalf?
No. The audit prepares you to talk to your regulators with confidence, but the engagement does not include direct regulator communication. That stays with your legal and compliance leadership.
What if the audit surfaces gaps we cannot fix in 90 days?
The remediation plan is sequenced by severity, not by what is convenient. Material gaps get a 30-60-90 day path. Less urgent items get a longer runway with named owners and milestones. If the surface area is wider than the audit can fully resolve, the AI Readiness Sprint or the Fractional CAIO retainer become the natural next step.