AI Acceptable Use Policy Guide (CARF) | Advantage Microsystems

AI Acceptable
Use Policy Guide

A starting point for CARF-accredited child and family service organizations at any stage of the AI journey.

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Staff are already using AI tools today, with or without guidance. The question isn’t whether your organization will engage with AI, it’s whether that engagement is deliberate. A written policy turns “we’re figuring it out” into a clear, documented stance your board, funders, and MCP partners can see.

Prepared for   Date
The 3-Stage Framework
1

Understand It Yourself

Build a personal baseline: try a real nonprofit-relevant prompt yourself before bringing anything to your team.

2

Establish Your Guardrails

A policy doesn’t need to be long, it needs to answer the eight decisions below clearly enough that any staff member can act on it.

3

Identify Your First Use Case

Start at the low-risk end of the ladder below: no client PHI, a real recurring burden, and a human review before anything ships.

First Use Cases, in Order of Risk

Start at 1. Earn your way to 5.

1

Grant Research & Drafting in an Enterprise Chatbot

No client data; human review before anything ships.

2

Staff Training Content

Internal-facing; mistakes get caught in review.

3

Family FAQs in Plain Language

External-facing; review for accuracy and reading level.

4

Meeting Summaries

Approved tool only, with your consent process in use.

5

Clinical Documentation & Case Notes

The biggest prize, and last for a reason. PHI at the center of the legal record: compliant vendor, BAA, consent workflow, and a pilot first.

5 Components Every Policy Should Cover

Approved Tools 1.A.5.a(1)

What staff may and may not use.

Prohibited Uses

No client PHI in consumer tools; no unapproved automation.

Confidentiality 1.A.5.a(3)

How HIPAA, CMIA, and 42 CFR Part 2 apply to AI-assisted work.

Staff Training 1.A.5.a(5)

Expectations and accountability for anyone using an approved tool.

Review Cadence 1.A.5.b 1.A.5.c

AI tools change rapidly; set a date to revisit the policy.

Building Your Policy: Eight Decisions

These eight decisions are a starting point for an AI policy. Work through them and fill in the boxes. Then review what you wrote with your compliance officer, legal counsel, and chief technology officer.

CARF added an AI standard to its ASPIRE to Excellence framework, effective July 1, 2026. In the 2026 Child and Youth Services Standards Manual, standard 1.A.5 requires written policies and procedures if your organization uses AI. They must cover how you use AI, disclosure to persons served, privacy of health information, protection of sensitive data, human oversight and accountability, and what counts as an incident, and be reviewed at least annually. This guide addresses these areas, and the tags show the matching part of the standard. Review the standard in your CARF standards manual with your accreditation consultant.
1

Sort Your Information Into Levels 1.A.5.a(3) 1.A.5.a(4)

A few clear categories, from regulated client data down to public material. The rules follow the information, not the device it is on.

Your information levels
2

List the Tools Staff May Use 1.A.5.a(1) 1.A.5.a(4) 1.A.5.a(5)

If it is not on the list, it is not approved. Confirm each vendor agreement actually covers the AI features, not just the product. Ask vendors to explain how the tool works, what data trained it, and whether that data represents the people you serve. Your data use agreements should limit how exported data can be used.

Your approved tools
3

Choose One Path for Sensitive Information 1.A.5.a(4)

Name a single approved tool for your most protected data. One clear path is followed more reliably than a set of exceptions.

Your one approved path for sensitive information
4

State What Is Off Limits 1.A.5.a(5)

Short, absolute rules that need no interpretation. A starting set is below.

Your own off-limits rules
5

Say What Happens When Something Goes Wrong 1.A.5.a(6)

Stop, do not delete anything, report right away. Name a contact and a number, and promise no retaliation for honest reporting. Define what counts as an incident, both inside the organization and to the person served, and who must be notified.

Who staff report to
6

Name an Owner and a Governance Committee 1.A.5.a(5) 1.A.5.b

One accountable person, plus a multidisciplinary committee that oversees your AI work. It can include clinicians, IT, legal counsel, and persons served. Its role is to vet new tools, create policies, and check compliance. The owner convenes it. Keep a clear chain of accountability, so that if an AI system contributes to an error or harm, you know who is responsible. Check the tools regularly for bias, data drift (when the data a tool was trained on no longer fits), and unexpected errors. Review policies at least annually, and again after any new tool, rule change, or close call.

Your owner and committee
7

Tell the People You Serve 1.A.5.a(2)

Disclose your use of AI in service delivery, and separately for any analysis or processing of their health information. Recording consent is not the whole obligation. Write the disclosure language once and use it consistently.

Your disclosure language
8

Train the Users and the Reviewers 1.A.5.a(5)

Regular training for staff using AI tools, and separate training for the people responsible for oversight. Training should cover how the AI works, what it can and cannot do, ethical considerations, and how to use it in daily work. Document who was trained and when.

Your training plan
A Starting Set of Off-Limits Rules
No client or organizational information in personal or consumer AI accounts.
No AI-generated clinical judgment: no diagnoses, assessments, or treatment decisions.
AI supports decisions and never makes them. Direct service staff always keep the final say on care decisions. 1.A.5.a(5)
Nothing AI produces gets filed or sent until a qualified person has reviewed and edited it. Someone is also accountable for reviewing AI output quality on an ongoing basis, not just item by item.
No AI note-takers or meeting assistants in client sessions until a documented consent process is in place.
Your most legally protected records stay out of every AI tool, without exception.
Before You Publish
Claim only the safeguards you have actually turned on. A policy describing controls you do not have is a liability, not a protection.
If you are accredited, expect to be asked during survey how your AI use is governed. A policy you cannot demonstrate in practice is worse than no policy.
Give staff a procedure for anything you require of them, not just the requirement.
Confirm what your vendor agreements cover. Do not assume.
A starting point, not legal advice. This guide is an educational resource. Your obligations depend on your programs, contracts, funders, and the populations you serve. Review any policy you adopt with your compliance officer and legal counsel before publishing, and revisit it with them as tools and regulations change. This guide addresses the areas the CARF AI standard describes, using standard 1.A.5 in the 2026 Child and Youth Services Standards Manual as its reference. Numbering in other CARF manuals may differ. It is not a substitute for the CARF standards manual or for guidance from your accreditation consultant.
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