Define authority by task, not by the words “estimator”, “reviewer” or “AI”.

Texas maintains a specific property-and-casualty adjuster licensing process, including non-resident and emergency routes. That is one reason to obtain state-specific advice for the proposed duties rather than assume a nationwide rule from a job title. Texas Department of Insurance. (tdi.texas.gov)

The NAIC’s adopted AI model bulletin addresses written AI programmes, governance, validation and third-party arrangements, and reiterates that AI-supported insurance actions must comply with applicable law. It is model guidance: counsel should check the relevant state’s position rather than treat it as one uniform federal requirement. Adopted model bulletin. (content.naic.org)

For the Evidence-to-Approval Control Audit, document who may prepare, amend, approve and release each output. Keep production acceptance separate from coverage, reserving and settlement authority, and make the retained reviewer’s access to underlying evidence a design requirement.