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Shadow AI Poses Greater Risks Than Most Health Care Organizations Realize, Report Says

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Shadow AI—the unauthorized use of AI tools by employees—is emerging as a major compliance and governance challenge for health care organizations, according to Wolters Kluwer Health’s 2026 predictions report. Shadow AI introduces significant concerns around data privacy, security, and regulatory compliance, particularly as generative AI tools become widely accessible. The report warns this issue is larger than most health care organizations realize, and failure to address it could lead to operational, legal, and ethical challenges.

While AI adoption in clinical decision-making and operational workflows is accelerating, many health systems are playing catch-up on policies and oversight, leaving gaps in policies and procedures. As employees become more comfortable with using general consumer tools in the health care setting, legal and reputational risk created by insufficient governance is compounded.

Recognizing this, providers and health systems should prioritize AI governance frameworks, update compliance policies, and educate staff on approved AI tools to mitigate shadow AI risks. HLB attorneys are actively helping organizations develop and evaluate compliance programs to strategically address these emerging challenges posed by the greater integration of AI into the health care environment.


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