Module 2 of 3 · 50 minutes
AI scribes and drafted records: what to check, and what to tell patients
By the end of this module you will be able to
- Explain what NHS England's guidance requires of organisations and of clinicians
- Explain when an ambient voice product is and is not a medical device
- Check an AI-drafted record using a repeatable routine
- Tell a patient clearly and honestly that a scribe is in use
- Correct and report an error in an AI-drafted record
Work through it
2 interactives for this module, built on the WAJD Teach engine. Nothing moves until you ask it to, and every one has a written version if you would rather read it.
Watch: Emma and George talk it through
5 minutes. Captions are on, and the same conversation is written out in full below. The voices are computer generated.
Emma George, scribes. Half my friends in the NHS say they're a miracle and the other half say they're a lawsuit waiting to happen. Who's right?
George Both, depending on whether the note gets checked. Let me start with what one actually does. It listens to a consultation or a handover, with permission, and drafts the note or the letter.
Emma And the benefit is real?
George Yes. Typing is time away from the patient, and trials have reported documentation time coming down. I'm not going to pretend that isn't valuable. But everything from the last module still applies. It can invent, omit, distort and misattribute, and it reads beautifully while it does.
Emma Is there actual guidance on this, or is everyone making it up?
George There's actual guidance. NHS England published it in April 2025 and updated it in July 2026. It's written for the organisations adopting these products, which is useful for you, because it tells you what to ask of yours.
Emma What should my organisation have done?
George Appointed a Clinical Safety Officer. Identified the risks and kept a safety case and hazard log, which is what the standard called DCB0160 asks of a deploying organisation. Done a data protection impact assessment. Checked whether the product counts as a medical device. And updated its privacy information before any recording started.
Emma That's a lot. Would I know if they hadn't?
George You can ask. Who's our Clinical Safety Officer? Is there a hazard log for this? Where does the recording go? If nobody can answer, that's information. It doesn't mean stop. It means ask your manager or your information governance team before you rely on it.
Emma And what does the guidance ask of me personally?
George Review and approve every output before it's acted on. You keep an ongoing responsibility to review and revise. And it says plainly that NHS organisations can still be liable for claims. So the organisation answers for the tool, you answer for the entry.
Emma I've also heard people argue these aren't medical devices at all.
George The MHRA clarified that on 29 July 2026. In summary, a product that supports diagnosis or treatment, or acts automatically without a clinician reviewing it, is a medical device. One that only transcribes, summarises, drafts letters or suggests codes for a clinician to review falls outside. Read their statement for the exact words, because this is a summary and positions get updated.
Emma So the line is a human reviewing it.
George Exactly. And you're the human. That's the design. Which is why I get nervous when people treat the review as a formality.
Emma Okay, give me the routine. I want something I can do in two minutes.
George Same order every time. Numbers first, doses and frequencies. Then negatives, denied and no and absent. Then sides and sites. Then medicines and allergies. Then who said what. And last, close your eyes and ask what was said that isn't there.
Emma And if I can't verify something?
George Don't sign it. Edit it or remove it. A shorter true note beats a fuller uncertain one.
Emma What do I say to the patient? I feel awkward.
George Keep it ordinary. A tool is going to listen and help me write the note. I'll check it. This is where the recording goes. You can say no. Clause 5.2 asks you to make sure people know how and why their information is used. If they say no, follow local policy and write it yourself.
Emma Last one. I find a mistake two days later. What do I do?
George Correct it through the proper route so the history is kept. Don't delete and rewrite. Report it as a patient safety event. And if it touched their care, be open and candid with them under clause 14.
Emma I think I'd be tempted to quietly fix it.
George I know. But a quiet fix looks like falsification later, and clause 10.3 is clear. An error that's caught and reported means the system works. That's the outcome you want.
The written material
What an ambient scribe does
An ambient scribe listens to a consultation or a handover, with permission, and produces a draft of the note or the letter. The promise is real: time spent typing is time not spent with the patient, and trials in several settings have reported documentation time falling.
The risk is also real, and it is the one from the previous module. The draft reads well. It may have invented, omitted or distorted something, and the better it reads, the less closely it tends to be checked.
What NHS England's guidance asks of organisations
NHS England published guidance on AI-enabled ambient scribing products in April 2025 and updated it on 29 July 2026. It is written for the organisations adopting these products, and it is worth knowing what it asks of them because it tells you what to ask of yours.
An organisation should appoint a Clinical Safety Officer, identify the risks and complete the clinical risk management documentation that NHS standard DCB0160 requires of a deploying organisation, including a hazard log. It should complete a data protection impact assessment. It should make sure the product has been correctly considered under medical device regulation. It should update its privacy information so that people are told what will be recorded, how outputs are stored and who will use them.
- Clinical Safety Officer appointed
- Hazards identified and a safety case kept (DCB0160)
- Data protection impact assessment completed
- Medical device status checked
- Privacy information updated before processing begins
What it asks of you
The guidance is direct about the individual. Users are to review and approve any product output before it is acted on, and the practitioner keeps an ongoing responsibility to review and revise it. It also says NHS organisations may still be liable for claims arising from the use of AI products.
Put the two together and you have the working rule. The organisation is responsible for choosing and governing the tool. You are responsible for the entry. Neither responsibility cancels the other.
Is it a medical device? The MHRA's July 2026 position
On 29 July 2026 the MHRA clarified the regulatory status of ambient voice technologies used in the NHS. In summary, products intended to support diagnosis, treatment or prevention, or that take automated actions without clinician review, are regulated as medical devices. Products used only to transcribe, to summarise a conversation, to draft letters or to suggest codes for a clinician to review fall outside medical device regulation.
The practical point for you is the phrase for a clinician to review. The dividing line is a human being in the loop, and that human being is you. The MHRA also asked NHS boards to assure themselves that deployment is supported by clinical oversight, local governance, staff training and procurement processes. Read the statement itself for the exact wording: this is a summary, and the position may be updated.
A routine for checking a draft, and for patients and errors
Check in the same order every time. Read for numbers: doses, frequencies, measurements. Read for negatives: denied, no, absent. Read for sides and sites. Read for medicines and allergies. Read for who said what. Then close your eyes for a moment and ask what was said that is not there. Edit rather than accept. If you cannot verify a line, do not sign it.
Tell patients before the tool starts, in ordinary words: that a tool will listen and help draft the note, that you will check it, where the recording goes, and that they can say no. Clause 5.2 asks you to make sure people are informed about how and why information is used and shared. If they decline, follow your local policy and write the note yourself.
If you find an error later, correct the record through the proper route so the history is kept, report it as a patient safety event, and if it affected care, be open and candid with the person under clause 14. An error caught is a system working. An error hidden is a different matter.
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