Control
No human review/data-correction path after adverse ADMT decision
After an adverse ADMT-influenced consequential decision, the consumer must be able to request data access/correction and meaningful human review + reconsideration.
Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.
Reach
enacted, not yet applying in Colorado (US-CO); next date 2027-01-01.
The guard to add
Give people who receive an adverse AI-influenced decision a way to see and correct the data used and to request human review that can change the outcome.
Built into the adverse-outcome path: when a decision is adverse, the system saves the personal-data inputs the model used with the decision, and the letter or screen that communicates it links to two routes. A data access and correction route (GET/PATCH /me/data, correct_input_data) shows those inputs and accepts corrections of inaccurate data, which send the decision back for re-run or review; a reconsideration route (POST /decisions/{id}/reconsideration, request_human_review) places the case in a review queue where a reviewer with authority to change the outcome records reviewer_id and override_reason.
Where it goes: 1 application source code, 9 AI output handling, 15 agent action surface, 2 data models.
What reviewers look for: for each adverse outcome that is saved and communicated, the inputs used stored with the decision, a person-facing route to view and correct them, and a reconsideration request that lands with a human reviewer who can change the outcome (reviewer_id, override_reason recorded); links to both routes in the adverse-outcome message.
Example (FastAPI), before:
if result['decision'] == 'denied':
applications.save(app_id, status='denied')
send_email(applicant.email, render('denial.txt', applicant=applicant))After:
if result['decision'] == 'denied':
applications.save(app_id, status='denied', inputs_used=features, model_version=MODEL_VERSION)
send_email(applicant.email, render('denial.txt', applicant=applicant,
data_url=f'{BASE}/me/data', review_url=f'{BASE}/decisions/{app_id}/reconsideration'))
@app.patch('/me/data')
def correct_input_data(fix: DataCorrection, user=Depends(current_user)):
corrections.create(user_id=user.id, field=fix.field, value=fix.value)
review_queue.enqueue(user.latest_decision_id, reason='data_corrected')
@app.post('/decisions/{decision_id}/reconsideration')
def request_human_review(decision_id: str, user=Depends(current_user)):
review_queue.enqueue(decision_id, reason='consumer_request') # reviewer can change the outcomeEngineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.
Upcoming dates
- : Consumers can request human review and data correction after an adverse ADMT decision (Colorado (US-CO); first application; stayed)
Every rule this guard addresses
Binding law — not yet in force or stayed (1)
- Colorado (US-CO)
- Consumers can request human review and data correction after an adverse ADMT decision C.R.S. 6-1-1705(1) · applies from 2027-01-01 · stayed
Standard / soft law (1)
- European Union (EU)
- AI systems should provide human oversight (HITL/HOTL/HIC) and the ability to intervene (EU ALTAI) ALTAI / EU Ethics Guidelines — Requirement 1 (Human Agency and Oversight)
Related incidents
No guardrail sits on this exact control; these incidents are cited by guardrails on related controls.
- UnitedHealth nH Predict claim-denial litigation (2023-11; alleged (not proven)). A class action filed in November 2023 alleges that UnitedHealth's nH Predict model had a 90% error rate, measured by denials reversed on appeal, while only about 0.2% of members appealed. UnitedHealth disputes the allegations; the litigation is ongoing. Source: STAT News · evidence grade: primary · cited by Monitor how often adverse AI decisions are reversed, and suspend models that are usually wrong
- Cigna PXDX batch claim denials (reported) (2022; alleged (not proven)). ProPublica, citing internal Cigna records, reported that Cigna's PXDX system was used to reject more than 300,000 claims over two months in 2022, with physicians spending an average of 1.2 seconds on each. Cigna disputes the reporting; related lawsuits are ongoing. Source: ProPublica / The Capitol Forum · evidence grade: press of record · cited by Make human review of adverse AI decisions substantive, not nominal