⚖️ UPHELD — Legal Risk: Unauthorized Practice of Law

Research by Max · February 2026 · n=20 sources · Confidence: Medium (requires licensed attorney review)

🎯 Bottom Line

Generating insurance appeal letters for patients is not clearly UPL — it sits in a gray zone that Claimable, Counterforce Health, and Fight Health Insurance are already operating in without legal challenge. The biggest risk factors for UPHELD specifically are the contingency fee model (which elevates UPL exposure significantly vs. flat fees) and auto-submission without patient review (which removes the "document preparation tool" defense). This is a manageable risk, not a blocker, but deliberate structural choices and a legal opinion from a healthcare/UPL attorney are required before launch.


Key Findings

1. Insurance appeals are administrative — this is the core legal protection

Insurance claim denials and appeals happen within the insurer's internal process and state insurance department review — they are not lawsuits. Courts consistently distinguish administrative advocacy (helping navigate a bureaucratic process) from practicing law (representing someone in court or giving specific legal advice). This distinction is UPHELD's primary legal shelter.

Source: BWJP UPL Matrix; ResolveMedicalBills.com | Confidence: High
2. "Practicing law" = specific legal advice + attorney-client relationship — not document generation

UPL definitions vary by state but share a core: practicing law means giving legal advice within an attorney-client-like relationship, or representing someone in court/quasi-judicial proceedings. Non-attorneys can help prepare documents and navigate administrative processes as long as they don't give specific legal advice ("you should sue," "your rights under this statute are X"). Patient billing advocates do this every day across all 50 states.

Source: California State Bar UPL definition; Lorman Education | Confidence: High
3. Multiple AI appeal startups operate today — without UPL prosecution

Claimable (covered by Forbes, Bloomberg, NYT, NBC News), Counterforce Health (NIH-funded), and Fight Health Insurance all generate AI insurance appeal letters for patients. None has been prosecuted for UPL. Claimable charges $39.95/appeal and includes clinical evidence and "relevant state and federal laws" in letters. Counterforce calls output "legal-grade appeal letters." Both operate openly with mainstream press coverage.

Source: Investopedia Aug 2025; NBC News Aug 2025; Counterforce Health / Claimable websites | Confidence: High

⚠️ DoNotPay: The Cautionary Tale

DoNotPay was fined $193,000 by the FTC (finalized Feb 2025) and faced class action lawsuits — but primarily for false advertising, not UPL. Calling itself "The World's First Robot Lawyer" while delivering sub-lawyer quality output triggered state bar investigations AND FTC consumer protection action. The lesson: never claim to be a lawyer or provide "legal services." Frame as document preparation, administrative assistance, or patient advocacy — never legal representation.

4. ERISA adds complexity — the administrative record closes after appeals

Under ERISA (covering ~60% of insured Americans via employer-sponsored plans), the administrative appeals record is the only record in any subsequent federal lawsuit. If an automated appeal misses evidence, misframes the argument, or makes errors, those may be permanently locked in. An ERISA attorney explicitly warns: "Submitting an AI-drafted appeal without review can damage your case and might permanently lock in errors." This is the strongest liability argument against full auto-submission.

Source: ERISA Recovery; Dorian Insurance Law blog Nov 2025 | Confidence: High
5. Contingency fee model significantly elevates UPL risk

Medical billing advocates commonly charge contingency fees for insurance disputes. However, when a non-attorney takes a percentage of a legal recovery — especially in ERISA or bad-faith insurance contexts — this begins to resemble attorney fee-sharing, which is prohibited in all 50 states (ABA Model Rule 5.4). NYSBA Ethics Opinion 1271 (Aug 2024) specifically affirmed that paying a % of legal fees to a non-lawyer online service violates Rule 5.4(a). The key question: are we recovering an administrative denial (probably OK) or a legal claim (much higher risk)?

Source: NYSBA Ethics Opinion 1271 Aug 2024; debofsky.com | Confidence: Medium-High
6. ABA Formal Opinion 512 (July 2024) focuses on lawyers, not non-lawyer AI tools

The ABA's first formal AI ethics guidance covers attorneys using generative AI — requiring competence, confidentiality, and human supervision. It doesn't directly govern non-lawyer AI document tools. No state has specifically prohibited AI-generated insurance appeal letters. The ABA's historical stance that non-lawyer document prep is UPL has been substantially softened by carve-outs in most states for standardized documents and form assistance.

Source: ABA Formal Opinion 512 Jul 2024 | Confidence: Medium
7. Auto-submission without patient review is UPHELD's unique risk

Every existing competitor generates a letter for the patient to review and send themselves. UPHELD's model (auto-generate AND auto-submit via FHIR API) is meaningfully different. When the patient reviews and chooses to submit, UPHELD is clearly a document-preparation tool. When UPHELD submits autonomously, it looks more like active representation — which triggers UPL analysis more acutely.

Source: Internal model analysis; Investopedia Claimable profile | Confidence: Medium-High
8. Patient authorization (written consent / ERISA designated representative) is a strong safeguard

Non-attorneys can act on behalf of a patient in administrative proceedings if the patient grants written authorization. ERISA regulations (29 CFR 2560.503-1) explicitly allow beneficiaries to designate authorized representatives. If UPHELD operates under explicit written patient authorization as a designated representative, this creates stronger legal ground — the company isn't practicing law, it's executing the patient's documented instructions.

Source: ERISA Regulation 29 CFR 2560.503-1 | Confidence: Medium

How Competitors Handle It

Company Model Fee UPL Risk Management
Claimable AI appeal after 25-min patient survey; patient reviews + sends $39.95 flat/appeal Flat fee (not contingency); patient-initiated submission; never called a law firm
Counterforce Health AI + expert team; NIH-funded nonprofit Free Nonprofit status; grant-funded; no financial stake in outcome; patient submits
Fight Health Insurance Chatbot + document upload; patient submits Free Free tool framing; no commercial UPL motive; patient submits themselves
Patient Advocate Foundation Human advocates help with appeals Free (nonprofit) Explicitly notes UPL limits; stays in "advocacy" lane; 501(c)(3)
ResolveMedicalBills Human billing advocates Contingency (% of savings) Explicitly warns advocates can't give "legal advice"; stays in admin advocacy lane
ERISA Recovery Former insurance pros recover underpayments Performance-based No attorney services claimed; targets billing disputes not legal claims; works alongside lawyers

Pattern: Every player either (a) keeps fees flat and non-contingent, or (b) operates as nonprofit/educational, or (c) explicitly disclaims legal advice and keeps humans in the loop. None auto-submits on the patient's behalf autonomously.


Risk Assessment

Risk Level Mitigation
UPL claim for generating appeal letters 🟡 Medium Frame as document preparation / patient advocacy. Clear disclosures. Never use "lawyer" or "legal advice."
UPL claim for contingency fee model 🔴 High Get legal opinion before finalizing fee model. Consider flat-fee or subscription pricing. If contingency, structure carefully with attorney guidance.
UPL claim for auto-submission without patient review 🔴 High Insert mandatory patient review + approval step. Patient clicks "Submit" — UPHELD does not submit autonomously.
FTC consumer protection action (false advertising) 🟡 Medium Never use "lawyer," "legal advice," "law firm" in marketing. DoNotPay is the exact cautionary tale to avoid.
ERISA liability for errors that close the record 🟡 Medium Prompt patient to review before submission. Prominently disclose ERISA record-closure risk. E&O insurance. Consider attorney review option.
State-specific UPL prosecution 🟢 Low No state has targeted health insurance appeal tools. Existing companies operate all 50 states. Standard disclaimers sufficient.
Class action (consumer protection) 🟢 Low-Medium Don't guarantee outcomes. Be accurate about success rates. Strong ToS. Avoid "robot lawyer" positioning.

Open Questions for Lawyer

  1. Contingency model: Is taking a percentage of recovered insurance proceeds (not "legal fees" but administrative recovery) permissible for a non-attorney company operating as patient advocate/technology platform? What structures reduce risk?
  2. Auto-submission: Does UPHELD submitting appeals via API (vs. patients self-submitting) trigger UPL or ERISA representation rules? Does the "authorized representative" carve-out (29 CFR 2560.503-1) protect us if we have written patient authorization?
  3. ERISA record closure: What language must we include in disclosures so patients understand the ERISA administrative record closes after internal appeals are exhausted?
  4. State-specific exposure: Which 3–5 states have the most aggressive UPL enforcement and should be specifically evaluated? (California and Virginia are historically aggressive.)
  5. Attorney partnership model: Would partnering with a supervising attorney (who reviews appeals) cure the UPL concern in a clean fee structure? What does that look like without violating fee-sharing rules?
  6. Marketing guardrails: What language triggers UPL/FTC risk ("legal services," "lawyer," "legal advice") vs. what's safe ("patient advocacy," "document preparation," "appeal assistance")?
  7. Error liability: What's the scope of liability if an auto-generated appeal locks in incorrect information that harms a patient's ERISA case in federal court? Is standard ToS sufficient, or do we need E&O insurance?

Sources

  1. BWJP UPL Matrix (2019) — bwjp.org
  2. California State Bar UPL definition — calbar.ca.gov
  3. ResolveMedicalBills — "Medical Billing Advocates and Lawyers" (Sep 2023)
  4. Dorian Insurance Law — "AI and Insurance Claims: Hidden Legal Risks" (Nov 2025)
  5. Investopedia — "AI Brings New Hope to Patients Battling Denied Health Insurance Claims" (Aug 2025)
  6. NBC News — "AI is helping patients fight insurance company denials" (Aug 2025)
  7. Counterforce Health website — counterforcehealth.org
  8. Claimable website — getclaimable.com
  9. FTC Press Release — "FTC Finalizes Order with DoNotPay" (Apr 2025)
  10. FTC Complaint — DoNotPay (Sep 2024)
  11. FKKS Technology Law — "DoNotPay Cases Underscore Hurdles for AI-Fueled Legal Help" (Apr 2023)
  12. ABA Formal Opinion 512 — "ABA Issues First Ethics Guidance on AI Tools" (Jul 2024)
  13. NYSBA Ethics Opinion 1271 — Sharing of Legal Fees with Non-Lawyer (Aug 2024)
  14. ERISA Recovery — "What is the ERISA appeals process?" (Oct 2025)
  15. debofsky.com — ERISA Litigation overview
  16. PatientAdvocate.org — "Navigating the Insurance Appeals Process"
  17. DiscoverHealthAdvocacy.com — Patient Advocate fee structures
  18. UpwardRiskManagement — "FTC Targets AI Litigation Tools" (Jul 2025)
  19. University of Washington Law Library — AI + UPL Ethics overview
  20. ERISA Regulation 29 CFR 2560.503-1 — Authorized Representative rules
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