Utah Lets AI Write First-Time Prescriptions in First U.S. Pilot

Utah has become the first U.S. state to authorize an artificial intelligence system to issue initial prescriptions, not just refills, under a pilot announced this week by a New York City-based digital health startup. The program, run through Nolla Health’s Nolla Derm app, allows an AI tool to prescribe topical acne treatments to Utah residents 18 and older, without an in-person office visit. It marks a significant test of how far regulators will let machines go in direct patient care — and how much physician oversight must remain in the loop.

The authorization was granted by the Utah Office of Artificial Intelligence Policy (OAIP), a state agency that operates a regulatory “sandbox” offering companies temporary relief from licensing rules to test AI products under medical supervision. Nolla said the approval came after months of work with the office.

How the Pilot Works

Utah residents who opt in pay a discounted pilot rate of $4.99 a month, excluding the cost of medication. After verifying their identity, giving informed consent and completing an intake questionnaire, patients take a “five-angle face scan.” According to ABC News, the system then generates a personalized treatment plan and, if appropriate, an initial prescription “in about 10 to 15 minutes.”

The AI is deliberately narrow. It does not use free text and cannot innovate beyond its instructions; instead, it selects among pre-approved topical treatment plans using structured clinical inputs and an assessment of the face scan. Severe acne, pregnancy and other conditions outside the pilot’s parameters are escalated to a licensed physician or in-person care. Oral treatments and isotretinoin are explicitly excluded, HLTH reported.

Three Stages of Physician Oversight

The pilot unfolds in three stages, each with a different level of human review:

• Stage 1 (first 100 patients): Two licensed physicians independently review and approve every AI-generated prescription before it reaches the patient. Runs at least four weeks.
• Stage 2 (up to 500 patients): The AI issues prescriptions directly, with a physician reviewing every case after the fact, at least weekly. Runs at least eight weeks.
• Stage 3 (ongoing): Physicians review at least a 10% monthly sample of prescriptions, plus every case involving an escalation or a side effect.

Advancing between stages requires meeting safety targets — including 95% agreement with physicians and zero serious adverse events — plus written approval from the state. Nolla says its clinicians agree with the AI’s treatment selections in 96% of real-world cases, with discrepancies limited to minor adjustments such as the strength of a topical.

“There’s been a lot of noise about AI in healthcare, and a lot of it deserves scrutiny,” Dr. Zaid Fadul, the pilot’s overseeing physician, said in the company’s announcement. “What sets Nolla apart is the clinical rigor behind it. The AI isn’t making freeform decisions. It’s selecting from pre-approved protocols reviewed by physicians, and clinicians are built into every stage.”

The Access Gap Behind the Bet

Nolla frames the pilot as a response to a severe shortage of dermatology care. In Utah, the company says roughly 100,000 people have active acne at any given time, but only 10% ever see a dermatologist. The average wait for a dermatology appointment in the state is about 61 days — nearly double the national median — and 11 counties have no dermatologist at all. A visit can cost up to $300, while untreated acne can lead to permanent scarring.

“AI will matter most in healthcare when it helps people get care they otherwise would not receive,” Nolla co-founder and CEO Luis Wenus said. “With Nolla Derm, we are showing how AI can responsibly expand that access and help someone get personalized treatment in minutes instead of long waits or going without care altogether.”

Zach Boyd, director of the OAIP, described the pilot as validation of the state’s approach. “The Nolla Health pilot program represents a significant step forward in leveraging AI to improve healthcare access for Utahns, while maintaining rigorous oversight and safety,” he said.

A Test Case With a Precedent

The pilot arrives against a contested backdrop. Utah previously allowed Doctronic to run an AI prescription-refill pilot, which drew a formal objection from the Utah Medical Licensing Board. The board argued that overseeing refills is “a task reserved for properly licensed medical practitioners for critical safety and clinical reasons,” and that the agreement had been signed “without consulting the Medical Board.” The state declined the board’s recommendation to suspend that pilot.

Nolla appears to have learned from that friction. The company said it met and worked directly with the Utah Medical Board before launch to reflect the board’s feedback in the final program — a notable contrast in process. Nolla has also raised $4.5 million in a round led by General Catalyst, and its app has been downloaded by more than 175,000 people across 44 states, though the AI-prescribing pilot is exclusive to Utah.

What to Watch

The program’s central unresolved question is evidentiary: the 96% clinician-agreement figure is the company’s own, and no independent clinical study has been published. Whether the model expands beyond acne — or beyond Utah — will likely depend on how the physician-review data holds up under scrutiny.

Utah has positioned itself as a national testing ground for AI in direct patient care, backing pilots that include a teen mental-health chatbot, Doctronic’s refill tool and Legion Health’s psychiatric medication renewals. Each has tested a different boundary of the same question: what may a machine decide on its own, and what must a human sign off on?

For now, the answer in Utah is cautious and staged — a first prescription written by software, but only under a doctor’s watchful eye.