We use AI tools in the practices we run, and we help clients choose and govern them. This is not an argument for or against AI in general practice. It is a plain account of what the RACGP currently says, what the RACGP’s 6th edition consultation draft expects, and the short list of things a practice should have in place before an assessor — or a patient — asks.
What the RACGP says today
The RACGP’s guidance on AI scribes is direct. An AI scribe automates parts of clinical documentation by turning the consultation into a draft note; it does not replace the GP, and GPs must review every note because scribes can produce errors and inconsistencies. The guidance lists the considerations a practice must work through:
- Consent. Obtain patient consent before using an AI scribe in a consultation. Some medical defence organisations recommend written consent, and recording laws vary across Australian jurisdictions.
- Privacy and data. Where the data is processed and stored — particularly outside Australia — and whether the vendor uses it for secondary purposes such as training its models. Read the terms and conditions before buying.
- Accuracy and responsibility. The GP remains accountable for the record. Review notes as soon as possible after the consultation and verify any suggested billing codes independently.
- Regulatory status. AI scribes are not currently regulated by the TGA as medical devices. There is no AI-specific legislation yet; new Privacy Act provisions take effect in December 2026.
The RACGP recommends practices develop a policy on which AI tools are permitted, update their privacy policy to tell patients AI is used, do due diligence on safety and efficacy, and have a backup process if the technology fails.
What the 6th edition draft expects
The consultation draft of the 6th edition puts AI inside the first standard, Foundations of general practice, alongside digital health. In our reading it expects a practice using AI to show patient consent and privacy handling, clinical accountability and human oversight, staff training, a risk assessment and an assessment of vendor suitability. That is the same list as the RACGP guidance, expressed as criteria an assessor can ask for evidence of. See our summary of the 6th edition draft.
What to have in place — now, under either edition
- An AI policy. One page: which tools are approved, who may use them, what they may and may not be used for, who reviews outputs, and what happens when they fail.
- A consent process. Built into booking confirmations, check-in and the consultation itself, with a record. Written consent where your MDO recommends it.
- An updated privacy statement. Patients told, in plain language, that AI is used, for what, and where data goes.
- A vendor review on file. Data location, secondary use, retention, security, and the vendor’s own terms — signed off before the tool is switched on.
- Training records. Every user trained on the policy, the consent step and the review-before-signing rule, with dates.
- A review habit. Notes reviewed and corrected before they are saved; billing suggestions never accepted unchecked.
- A fallback. What the doctor does when the scribe is down. Usually: type, as before.
Our view: AI governance will be one of the first things a 6th edition assessor asks about, because it is new, it is easy to evidence, and it separates practices that run systems from practices that bought software. A practice with the seven items above will pass that conversation in five minutes.
Beyond scribes
AI is also arriving in triage and phone answering, recall and reminder wording, coding suggestions, practice analytics and patient-facing chat. Each raises the same questions — consent, privacy, oversight, training, vendor — and the same one-page policy covers them if it is written as a framework rather than a product list. We set this up as part of compliance documentation and IT & systems.
- RACGP — Artificial intelligence (AI) scribes
- AGPAL — Artificial intelligence in general practice: industry guidance
- RACGP Standards for general practices 6th edition, consultation draft (structure may change on publication).
General information, not legal or medico-legal advice. Check the current RACGP guidance and your medical defence organisation.
Quick answers
Do we need patient consent to use an AI scribe?
Yes. The RACGP’s guidance is that GPs must obtain consent from patients before using an AI scribe in a consultation, and some medical defence organisations recommend written consent. Recording laws also vary by state. Build consent into the booking and check-in process rather than relying on the doctor to remember.
Are AI scribes regulated by the TGA?
According to the RACGP, AI scribes are not currently regulated by the TGA as medical devices, because the GP independently determines the clinical content and billing. That puts responsibility for accuracy squarely on the clinician who reviews and signs the note.
What will assessors ask about AI?
Under the 5th edition, AI sits inside existing privacy, consent and records criteria. The 6th edition consultation draft names it directly: patient consent and privacy, clinical accountability and human oversight, staff training, risk assessment and vendor suitability. Expect to show a policy, a consent process, an updated privacy statement, training records and a record of the vendor review.
Fifteen years in medical practice operations. MBA, Melbourne Business School. Two medical centres built and sold; ten-plus centres overseen today. About Jamal →