Artificial Intelligence - What does this means for Healthcare?
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Artificial Intelligence - What does this means for Healthcare?

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Ireland

Artificial Intelligence ("AI") continues to develop at an explosive rate and is transforming our relationship with technology which requires society to consider how best to use it both socially and economically. 

AI Advisory Council

In our previous article which you can find here, we discussed the introduction of Ireland's National AI Strategy which made provision for the establishment of an AI Advisory Council in January 2024. The AI Advisory Council represents a spectrum of experience and expertise from academia, business, law, security, social sciences, economics and civil society.

As the Advisory Council enter their second year, they are now well established and actively reporting on "key opportunities and strategic policy recommendations aimed at accelerating AI adoption in Ireland while safeguarding the nation's economy, competitiveness, workforce and society."

You can view their latest report published on 21 February 2025 here

The report outlines six critical areas and provides commentary on same:

1. AI and the Future of Skills and Work: There remains uncertainty in respect of the transformative impact that AI will likely have on the labour market in Ireland. The Advisory Council opines that Ireland needs to develop policies that can be sufficiently robust to a wide range of possible future scenarios to assist with navigating the changes ahead. 

2. AI Ecosystem: Strategies to lead in applied AI: Ireland has positioned AI as a driver of economic growth and is well positioned to be a leader of accelerated AI. The Advisory Council outline the importance of supporting start-ups and SMEs, accelerating funding, leveraging and expanding existing testbed initiatives, and unifying vision for growth.

3. AI Literacy and Education: The Advisory Council's recommendations relate to the use of Generative AI in the primary / post-primary / third-level and further education sectors. The Council recommends that the Government should create and publish guidelines for the use of generative AI that can be quickly updated as technology involves and emphasises the importance of AI literacy training for educators and ensuring equitable access to AI tools in education.

4. AI Sovereignty and Infrastructure: The Advisory Council recommends that the Government should fully integrate AI into its operations for streamlined public services emphasising and recognising the value of sovereign data and highlighting the importance of investment in energy infrastructure to our future participation in the AI economy.

5. Biometrics and the Public Service: The Advisory Council is conscious of the opportunities and challenges Facial Recognition Technology (FRT) will bring and provides recommendations for the responsible use of AI powered FRT in public services i.e. the need for a bespoke procurement framework, testing prior to commencement and subsequent auditing as a safeguard.

6. AI and Ireland’s Creative Sector: The Advisory Council is aware that AI technology is transforming Ireland's creative sector. The Council opines that it is imperative that the Government consider whether Ireland's copyright laws and licensing regimes are equipped to address AI disruption in order to protect creators. The Council also recommends that in the age of deepfakes and digital cloning, the Government should consider introducing a specific law prohibiting the creation of digital "deep fakes" of individuals without their consent. 

Healthcare

As touched upon above, AI is having a transformative impact on all aspects of society and the field of Healthcare is no different. 

The Irish Platform for Patient Organisations, Science and Industry ("IPPOSI") convened a "Citizens Jury" of 24 individuals, representative of the population of Ireland, to make recommendations on the use of AI in Ireland's healthcare system. Members of the Jury were selected from applications received and an algorithm, designed by Trinity College Dublin, was used in the selection process. The selection process was then overseen by an Oversight Panel comprising of independent experts in the fields of "public participation, citizen and patient advocacy, health policy, health care, health research and AI."

On 21 February 2025, the IPPOSI published its verdict and you can view the Citizens' Jury report here.

In their open letter to the Minister for Health and the Minister for Enterprise, Tourism and Employment, the Jurors outline their fundamental belief that "AI in healthcare should always work alongside humans, never replacing them."

The Jury report identifies 25 recommendations for health policy-makers to consider which have been helpfully summarised in the report and are set out below:

1.    "Human oversight: The provider-patient relationship should remain the primary focus of healthcare. This means there should be human oversight at all points of AI-enabled healthcare, from its development to its deployment. 

2.    Equitable access: The use of AI-enabled care should be equitably accessible to all, and there should be no distinction between care accessed publicly or privately. 

3.    Patient rights: The implementation of the EU AI Act should be enshrined in national legislation, and there should be special provision to protect health data relating to AI. 

4.    Domestic legislation: The Attorney General should advise the Government on enacting additional legislation this year to close gaps in the EU AI Act, ensuring safeguards against the misuse of health data by exempt entities. 

5.    National strategy: A national strategy on the use of AI in healthcare in Ireland should be published in 2026.

6.    Public benefit: The benefits of using AI in healthcare should be returned to the public to reflect the valuable contribution made to innovation by sharing their health data.

7.    Multi-year investment: The Government’s budget should allocate adequate, multiannual funding to begin investment in quality AI systems for healthcare in Ireland. 

8.    Regulatory body: A fully-representative, multi-disciplinary statutory body should be established in 2025 to regulate and enforce standards around the use of AI in healthcare, including licensing, compliance monitoring, and imposing penalties. 

9.    Public education: A clear and accessible national engagement campaign should be implemented in 2026 to communicate the timeline, the scope, the goals, and the benefits and risks for the public regarding the use of AI in healthcare. 

10.    Public involvement: A first phase of 12 pilot programmes should be identified and financially supported by 2027 to roll out the use of AI solutions in healthcare. There should be opportunities for the public to volunteer to participate in these initiatives. 

11.    Early use: The use of AI in healthcare should be prioritised in areas where the public believe it can be most of use, including administration (referrals, waiting lists), image analysis, robotic surgery, medical research, and medicines research and development. 

12.    Informed consent (AI care): The right to opt out of AI-enabled care should be protected. 

13.    Contingency planning: A multi-stakeholder Task Force should be established by the end of 2026 to develop a contingency plan in the event of an AI failure in healthcare.

14.    Ambient AI: The use of “ambient” AI voice technology by health and social care professionals should be supported, including financially. 

15.    Digitally-enabled care: The Digital for Care Framework, in particular the solution for a national electronic health record system, should be urgently and fully implemented to provide the foundations for the deployment of quality AI solutions. 

16.    Interoperability: A centralised, accessible, and interoperable approach should be established to provide access to AI data, tools and systems pertaining to healthcare. 

17.    Organisational policy: All major healthcare settings should be required to develop organisational policies on AI within the next 12 months.

18.    Workforce training: An education and training curriculum around the use of AI in healthcare should be developed and delivered to qualified medical professionals, as well as to students in training.

19.    Research: The Health Research Board and Research Ireland should be given additional resources in the Government’s Budget 2026 to fund research projects that explore or support the use of AI in healthcare. 

20.    Informed consent (AI training): The health data used to train AI systems should be transparent and inclusive, and the auto-enrolment of everyone’s health data into the training of AI should include an option to “opt out”. 

21.    Independent Commissioner: An Independent Commissioner role should be established by 2026 to act as a watchdog for the public interest, and to advise on regulation regarding specific uses of AI in healthcare. 

22.    Equitable access: The datasets used by AI systems operating in the Irish health system should be regularly updated to capture new patient characteristics and rare disease diagnoses. 

23.    European priority: An EU Task Force should be established by Irish MEPs in the second half of 2026 to explore how regulation can help the EU to keep pace with the use of AI in healthcare, and to support Member States to take a consistent and coordinated approach to the implementation of regulation. 

24.    Data security: An appropriate regulator should be mandated to implement robust measures to protect and secure data integrity within AI systems by the end of 2026.

25.    Human-led design and development: The designers and developers of AI solutions for use in healthcare should be required to integrate the principle of "human in the loop" into each aspect of the design and development process."

What next?

AI has well and truly arrived in Ireland. The Jury Report has been published and it remains to be seen what recommendations, if any, the Government will implement. We will continue to blog in this area as matters develop.  

Written by: Sinéad Taaffe, Damien Watson 
 

Areas of Expertise

Public and Regulatory