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Utah approves first AI system to issue initial prescriptions

Utah approves first AI system to issue initial prescriptions

New Capabilities

Nolla Health's Nolla Derm app writes acne prescriptions, with Utah physicians checking the work in stages

October 5th, 2026: Nolla Health receives first U.S. approval for AI-issued initial prescriptions

Overview

Updated Oct 26

Adults in Utah with mild to moderate acne can get a prescription written by an AI system, with Utah physicians checking the work. Nolla Health's Nolla Derm app scans a face, grades severity and picks from eight topical treatments under an agreement that runs to October 5, 2027.

The state's published terms bar the AI from treating severe acne or prescribing to anyone who is pregnant, breastfeeding or has a weakened immune system, and orders go only to Utah addresses after a photo ID check. Two physicians review every prescription at first; the final stage drops to a monthly sample of at least 10%. Federal questions remain, because the agreement cannot waive FDA device rules or shield the pharmacies that fill the orders.

Why it matters

If the pilot works, AI prescribing could expand beyond acne to other routine conditions, changing who writes prescriptions and how patients access care.

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Key Indicators

$4.99
Monthly subscription cost
Discounted rate for Utah residents opting into the Nolla Derm pilot.
95%
Agreement needed to loosen oversight
Utah requires at least 95% concordance between AI prescriptions and reviewing physicians before it allows less human review.
8
Skin treatments AI can prescribe
All topical. The system cannot prescribe oral medication or isotretinoin.
3
Physician oversight stages
Review of every prescription, then review after the fact, then a monthly sample of at least 10% plus every escalation.

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People Involved

ZB
Zachary Boyd
Director, Utah Office of Artificial Intelligence Policy
Authorized the Nolla Health pilot
SG
Sara Gerke
Professor of Law, University of Illinois Urbana-Champaign College of Law
Raised federal regulatory questions about the Nolla Health pilot

Organizations Involved

Nolla Health
Nolla Health
Healthcare startup
First U.S. organization authorized for AI to issue initial prescriptions

AI-powered personal healthcare company based in New York City
UO
Utah Office of Artificial Intelligence
State agency
Authorized the Nolla Health pilot

State office that regulates AI systems in Utah.

Timeline

2026 October 2026

3 events Latest: October 5th, 2026 · 1 month ago

  1. Nolla Health receives first U.S. approval for AI-issued initial prescriptions

    Latest Regulatory

    Utah's Office of Artificial Intelligence authorized Nolla Health's AI to issue initial acne prescriptions through the Nolla Derm app, the first such approval in the country.

  2. Utah approves slate of AI health pilots

    Regulatory

    The Utah Office of Artificial Intelligence Policy announced three clinical pilots, from Expect Fitness, August AI and Nolla Health, and added healthcare as a pillar of its 'Pro-Human AI Initiative.' The office also announced agreements with two health systems for future AI pilots.

  3. Utah allows AI to renew certain medications

    Regulatory

    Utah began permitting AI systems to renew certain medications, a precursor to the Nolla Health approval.

Scenarios

1

Nolla Derm expands to new conditions beyond acne

Possible Resolves by Oct 5, 2027

Discussed by: Nolla Health has said acne is the right starting point for AI in healthcare, implying other routine conditions could follow.

If the pilot meets safety targets, Nolla Health could seek approval for additional low-risk conditions. The company has described acne as a well-understood, low-risk condition with decades of clinical evidence, suggesting a template for other routine dermatology or primary care cases.

2

Utah suspends AI prescription pilot after safety concerns

Unlikely Resolves by Oct 5, 2027

Discussed by: The pilot's staged oversight and safety targets suggest regulators are monitoring closely for adverse events.

If the AI issues a harmful prescription or misses safety targets, the Utah Office of AI Policy could suspend the program. The pilot requires 95% agreement with physicians and zero serious adverse events to advance between oversight stages.

3

Pilot completes first year, renews for two more

Likely Resolves by Oct 5, 2027

Discussed by: The program is structured to operate for a year with potential renewal at the discretion of the Utah Office of AI Policy.

If the pilot meets safety targets and shows strong clinical performance, the Utah Office of AI Policy could renew the program for two additional years. The renewal decision rests with the office that authorized the pilot.

4

FDA requires premarket review of Nolla Derm before it can expand

Possible Resolves by Oct 5, 2027

Discussed by: Sara Gerke, professor of law at the University of Illinois Urbana-Champaign College of Law

Nolla Derm operates under a Utah sandbox, but federal law may treat the AI as a medical device. If the FDA asserts jurisdiction, Nolla Health may need to pause or alter the pilot while seeking premarket clearance.

5

Pharmacies refuse to fill AI-written acne prescriptions

Possible Resolves by Oct 5, 2027

Discussed by: Holland & Knight health lawyers

The Utah agreement binds Nolla Health and its associated physicians, not the pharmacies that fill the orders. Holland & Knight notes that pharmacies get no protection from state enforcement and must decide how to verify an AI-flagged prescription and when to call the supervising physician. A refusal would leave a patient holding a prescription that is valid under state rules but unfilled.

Historical Context

2 moments from history that rhyme with this story — and how they unfolded.

March 2020

Telemedicine waivers during COVID-19 (2020)

At the start of the pandemic, the federal government and states waived requirements that doctors see patients in person before prescribing. Medicare began paying for telehealth visits at the same rate as in-person visits.

Then

Telehealth use surged during the pandemic and remained elevated afterward.

Now

Many states made telehealth waivers permanent, expanding remote healthcare access.

Why this matters now

Like the telehealth waivers, Utah's approval of AI prescribing relaxes a long-standing requirement that a licensed physician issue prescriptions, to expand access to care.

September 2014

First autonomous vehicle testing permits (California, 2014)

California's Department of Motor Vehicles began issuing permits for companies to test autonomous vehicles on public roads, creating a regulatory framework for a technology with no clear legal path to deployment.

Then

Companies including Google and Tesla began testing autonomous vehicles in California.

Now

Other states followed with their own frameworks, and autonomous vehicle testing expanded nationwide.

Why this matters now

Utah's approach to AI prescribing mirrors this pattern: a state creating a controlled regulatory framework for a new technology, with other states likely to follow.

Sources

(22)
+16
PRNewswire Nolla Health Bloomberg Law The Verge Becker's Hospital Review The Seattle Times Medical Economics Business of Fashion Inc. Techlantis Healthcare Dive ASCO AI in Oncology The Innovation Attorney Healthcare Brew Good Morning America WebProNews Wellworthy Health Exec Utah Governor's Office of Economic Opportunity Holland & Knight The BMJ Becker's Hospital Review