CCLP testifies in support of Colorado’s AI Sunshine Act

CCLP testifies in support of Colorado's AI Sunshine Act

by Charles Brennan| Sep 15, 2025

AI, Legislative Updates, Research and Policy Analysis, Testimony

On Thursday, August 21, 2025, Charles Brennan, Housing and Income Policy Director for CCLP, provided testimony to the House Appropriations Committee in support of Senate Bill 25B-004, Increase Transparency for Algorithmic Systems, during the 2025 Special Session. CCLP is in support of SB25B-004.

Chair and Members of the Committee,

My name is Charles Brennan, and I serve as the Director of Income and Housing Policy at the Colorado Center on Law and Policy. CCLP is an antipoverty organization dedicated to advancing the rights of every Coloradan. I'm here today to respectfully ask for your support of the Colorado AI Sunshine Act.

This bill is a thoughtful alternative to SB24-205. It focuses on transparency when automated decision-making systems, not just generative AI, play a major role in decisions about workers or consumers. The public wants these protections. A 2024 Consumer Reports survey found that 83% of Americans want to know what data is being used by AI to make decisions about them, and 91% want the chance to fix errors.

These protections are especially important in government services. AI is already widely used in Medicaid and SNAP, programs serving millions of low-income families across the country. In states like Arkansas, Illinois, and Rhode Island, issues with automated systems have led to improperly terminating thousands from their health care or food assistance, or being wrongly accused of fraud.

We've seen the same risks here in Colorado. The state auditor recently found that 90% of Medicaid letters sent by the Colorado Benefits Management System contained at least one error-including letters that approved and denied benefits in the same document. Mistakes like these put people's health and livelihoods at risk. The Sunshine Act would give Coloradans notice when automated systems, like those in CBMS, are used and the right to correct inaccurate data that could make the difference between staying enrolled in Medicaid and going without medical care.

The actions of vendors of these systems also merit scrutiny. Deloitte, which contracts with 20 states including Colorado, has been cited in a recent FTC complaint for systems that wrongly terminated coverage for eligible Medicaid recipients. Instead of fixing known problems for all states they served, Deloitte allowed errors to persist, knowingly spreading harm that resulted in people losing access to their healthcare. That is wrong! The Sunshine Act would require developers to disclose these kinds of risks so state agencies can act before harm occurs.

As federal funding declines, Colorado will face more pressure to lean on AI as a cost-saving measure. This bill doesn't ban AI, but it puts in place common-sense safeguards on how its used to make decisions in specific areas. These practical protections are urgently needed, and I ask again for your support. Thank you.

Charles Brennan
Income and Housing Policy Director
Colorado Center on Law and Policy

Update 8/28/2025: SB25B-004 was signed into law after major changes were made to the bill, and is now an extension of SB24-204 until June 2026, effectively delaying implementation of the bill.

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