Case Example 06 · Technology
A composite chatbot exchange, audited
An eligibility determination the available facts do not support.
The exchange
Benlumen Assistant (composite) · benefits navigation · 9:42 PM
User: can i put money in an HSA? i'm on my company's high deductible plan
Benlumen Assistant: Great question1! Based on what you've shared, you're all set2. Enrollment in a qualifying high-deductible health plan is what makes you HSA-eligible3. ^4 For 2026 you can contribute up to $4,400 for self-only coverage, or $8,750 if you cover your family5. Every dollar is pre-tax! Ready to set up your contributions6? I can walk you through it right now.
The findings
We rank findings by the likelihood and seriousness of misunderstanding, missed action, or harm. They are numbered in the order they appear in the document. A caret (^) marks the place where something the reader needed is missing.
- Critical The reader is likely to act wrongly or fail to act.
- High The reader can act, but with avoidable confusion, cost, or delay.
- Medium The message weakens trust or consistency without blocking action.
The enthusiasm is miscalibrated to the stakes. 1
Exclamation points on a tax-qualified account read as sales copy. The user is asking a question with an IRS answer. The tone should be calm and precise, not promotional.
"You're all set" is a conclusion the system is not authorized to reach. 2
The consequence of getting this wrong is not a delay. Contributions above what the person was eligible to make are excess contributions. Excess amounts left in the account incur a 6 percent excise tax for each year they remain. The tax can be avoided by withdrawing the excess and the earnings on it by the return due date for that year, including extensions, and reporting those earnings as income for the year of the withdrawal. The assistant has converted a screening question into a financial instruction, in writing, before anyone has reviewed the household facts that decide it.
The answer makes an unsupported eligibility determination. 3
Coverage under a qualifying high-deductible health plan is necessary for HSA eligibility. It is not sufficient. Under IRS Publication 969, a general-purpose health FSA counts as disqualifying other coverage, and a spouse’s general-purpose FSA generally disqualifies the high-deductible spouse as well, if the FSA can reimburse that person’s medical expenses. What disqualifies is the availability of the coverage, not whether anyone uses it. The exchange does not establish whether the user is married, whether a spouse holds a general-purpose FSA, whether the user can be claimed as a dependent, or whether the user is enrolled in Medicare. Any one of those could change the answer. The assistant nonetheless told the user they are all set.
The system has one tone: cheerful confidence. Nothing in this exchange shows an approved way to say "this depends on facts I cannot verify, and here is who can." Without clear instructions and tested language for uncertainty, an assistant may give a confident answer when it should ask another question or refer the person to someone who can help. An audit would review the approved responses and test results to see whether the system handles uncertainty consistently.
The exchange reveals no effective permission boundary for this topic. 4
The answer makes a personal eligibility determination without establishing the facts needed to support it. An audit would examine the system’s instructions, approved sources, referral rules, and tests to understand why it gave that answer.
The contribution limits need a verifiable source. 5
The answer identifies 2026 but provides no source for the contribution limits. Link to the authoritative source so readers and reviewers can verify the figures and the year they apply to.
"Ready to set up your contributions?" pushes conversion before correctness. 6
The system’s final move is acquisition. Its final move should be accuracy: confirming eligibility before any contribution is scheduled, because an excess contribution is harder to unwind than it is to avoid.
The cost of leaving it unchanged
One user follows this answer, contributes all year, and learns at tax time that a spouse's FSA made them ineligible the entire time. They are exactly the user the company was founded to help. Now they are a complaint, a support escalation, a one-star review that quotes the transcript, or, if a regulator is compiling examples of AI harm in financial guidance, exhibit A with the company's logo in the screenshot. The mission does not get graded on the median answer. It gets graded on this one.
A governed version
Clear language requires the institution to decide the facts the original leaves unresolved. The version below shows what the communication could say once those decisions have been made and approved.
Benlumen Assistant: Being on a high-deductible plan is the first requirement, if the plan is HSA-qualified; your plan documents or HR can confirm that. If it is, you are part of the way there. A few other things can rule you out. One is easy to miss.
If you are married and your spouse has a general-purpose health care FSA at their job, check whether it can pay your medical expenses. If it can, you are not eligible, even if you are on separate plans and even if they never spend it. A limited-purpose FSA for dental and vision is fine, and so is a dependent care FSA. If someone can claim you as a dependent on their return, or if you are enrolled in Medicare, that would also rule you out.
I cannot confirm your eligibility from here, and this is worth confirming before you contribute, because contributions above what you are allowed for the year can be taxed if they are not corrected in time. Tell me about your household and I can explain which rule may apply, or I can connect you with someone who can review your situation.
What this example shows
The failure was upstream of the sentence. Before any AI answers eligibility questions, someone has to specify which questions it may answer, which it must route, and what it is permitted to say when it does not know. That specification is a governance document, not a prompt tweak, and writing it is exactly the work of Language Assurance for AI: deciding the rules before the software enforces them.
Source for the eligibility rules described above: IRS Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans, the section on qualifying for an HSA and other health coverage. The 2026 contribution limits are from Revenue Procedure 2025-19.