What should the buying group do over the next 90 days?

Immediately: repair current-control gaps

• Claims operations: test the Washington workflow against the rules already effective on 18 October 2026.
• Technical QA: review a sample of database-led scope or pricing decisions and their supporting investigations.
• Security: verify the actual production-provider access environment against the applicable New York requirements.
• Legal and AI governance: decide whether to participate in Colorado’s 26 October and NAIC’s 30 October comment processes. (insurance.wa.gov)

Within 30 days: revise the specification

Complete the applicability register; identify unsupported supplier promises; revise the acceptance checklist; and document the boundary between preparation, recommendation and authorised claims action. Make unresolved legal interpretations explicit rather than embedding them silently in automation rules.

Within 60 days: run a control-focused pilot

Test representative routine water and wind files separately from smoke, catastrophe and coverage exceptions. Include a claimant-file export, an estimate-source enquiry, a reviewer override, an adjuster handover and a reopened-file event. Measure the time and defects associated with each exercise.

Within 90 days: contract for the retained work

Specify who owns updates, who pays for production-originated corrections, how subcontractor changes are approved, what cooperation is available during regulatory enquiries and what the carrier receives on exit. Record any capability the carrier must retain because the supplier cannot demonstrate it.

The buying decision should answer one question: does this arrangement reduce the total work required to produce an accepted, defensible claim file—or merely deliver the first draft sooner?