Comment from Collision Safety Consultants of WV

I appreciate the Commission's efforts to address the growing use of artificial intelligence in consumer-facing industries and respectfully submit the attached letter for the Commission's consideration. While the proposed policy statement focuses primarily on undisclosed ideological manipulation of AI systems, I encourage the Commission to consider a broader consumer protection concern: the increasing use of AI and algorithmic decision-making in the insurance claims process. Insurance claims involve contractual rights, financial obligations, and decisions that can significantly impact consumers. Policyholders reasonably expect these decisions to be based upon the insurance contract, applicable law, and an objective evaluation of the available evidence by qualified professionals. As AI becomes increasingly integrated into claim handling, consumers deserve transparency regarding when and how these systems materially influence decisions affecting their rights. My concern is not the use of AI itself. Artificial intelligence has tremendous potential to improve efficiency, organize information, reduce administrative burdens, and assist licensed professionals. The concern arises when AI materially influences claim outcomes without meaningful transparency, independent human review, or clear accountability. Consumers should reasonably know: When AI materially influenced a claim decision or recommendation. Whether a licensed adjuster independently evaluated the evidence or merely approved an AI-generated recommendation. Whether AI outputs were influenced by predetermined business rules, optimization objectives, or other undisclosed factors. Whether insurers and regulators can meaningfully audit AI-assisted decision-making. These concerns are no longer theoretical. Independent research has documented known limitations of current AI systems, including the ability to generate confident but inaccurate outputs. Insurance regulators, including the National Association of Insurance Commissioners and several state insurance departments, have already issued guidance addressing AI governance, transparency, accuracy, and consumer fairness. Litigation and regulatory actions involving automated insurance decision-making likewise demonstrate that these issues are already affecting consumers. From a consumer protection perspective, the undisclosed objective is often less important than the undisclosed influence. Whether AI outputs are shaped by ideological, commercial, financial, operational, or other objectives, consumers deserve transparency whenever those influences materially affect decisions impacting their contractual rights. I respectfully encourage the Commission to consider the attached letter, which expands upon these issues, discusses the application of the Commission's "reasonable consumer expectations" standard to AI-assisted insurance claims, and provides supporting references to regulatory guidance, published research, and relevant litigation. Thank you for the opportunity to provide these comments and for considering the attached submission.