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Why combining AI with human empathy is vital to drive down PMI and protection complaints – analysis

by Graham Simons
13 August 2026
FOS receives fewer health and protection insurance complaints but upholds more
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The first part of Health & Protection’s analysis into increasing customer complaints about private medical insurance (PMI) and protection cover revealed myriad factors are at play.

This second part looks into possible solutions to arrest this increase as it appears improvements in service levels could be made across providers and advice firms.

While artificial intelligence (AI) offers some hope of speeding up processes for protection and PMI claims, this technology can prove a mixed blessing as the need for human interaction remains.

Consequently, it appears that effective grievance monitoring and the human beings of the sector coming together are essential to making the difference in meeting the challenge of driving down customer complaints.

 

Clear communication

“We believe that starts with designing products that are simple to understand, supporting them with clear, straightforward communication throughout the life of the policy,” Rachael Welsh, head of commercial strategy at Guardian, tells Health & Protection.

“We work hard to make our definitions as clear as possible, avoid jargon wherever possible, and remind our customers what they’re covered for through our anniversary emails.

“We’ve recently simplified our terms and conditions by separating them by cover type, so customers only receive information relevant to their policy. 

“This year we’ve further improved our adviser and customer dashboards to make cover easier to understand and engage with.

“When customers understand what they’ve bought and why it matters, they’re more likely to value their cover, have a positive experience when they interact with it, and are less likely to raise complaints because expectations and outcomes are aligned.”

 

Understanding their cover

But not all customers know which type of protection cover fits their needs.

Peter Hamilton, head of market engagement at Zurich, tells Health & Protection: “As an industry, we have more to do to help customers better understand the nature of the cover they have, but we’re not seeing that driving material numbers of FOS referrals.”

Picking up on a trend pointed to by Velvet’s Joanna Streames in Health & Protection‘s initial analysis, Hamilton adds that the sector has seen an increasing use by customers of AI to craft complaint letters.

“This is a trend that is not limited to insurance, but is being seen across industries, and again, is unsurprising,” he continues.

“The most obvious thing advisers can do to help reduce complaints is to ensure customers understand the importance and the reasons for full disclosure when taking out a policy at the outset.”

In terms of accelerating these processes, it appears AI offers an answer, and it is clear that advisers and providers alike have been investing in this technology.

The final big project Sheldon Mills worked on ahead of leaving the FCA after eight years at the regulator in July was on the impact of AI on financial services.

Within his findings, while Mills suggested AI could help tackle the protection gap, he warned the technology may also lead to more hyper-personalisation, making the market more opaque.

 

Opportunities and threats

Though again, it appears providers are aware of the risks and opportunities that AI brings in helping meet good outcomes under the Consumer Duty.

Gabrielle Best, service operations manager at Cirencester Friendly, says: “There are opportunities and threats. 

“There is a danger that AI could negatively impact customer service if it makes it more difficult to speak to a human. Protection claims require empathy and understanding. 

“We are committed to keeping customer service personal, while exploring how AI can enhance efficiency while keeping human expertise and interaction at the heart of our service.

“Relying too heavily on any automation could lead to more complaints, especially given the sensitive issues our customers often have. 

“Finding the right balance between technology and human support will be key to delivering good outcomes.”

Impact of AI

But these opportunities and threats apply equally to private medical insurance, and Duncan Reeves, chief operating officer at National Friendly, stresses the importance of not assuming that an increase in complaints automatically reflects a decline in customer service.

“Consumers today have more information and more tools available to them than ever before,” Reeves says.

“Artificial intelligence can help people understand policy terms, compare wording and draft complaints quickly, which may encourage some customers to challenge decisions they might previously have accepted.

“In that respect, AI has the potential to increase complaint volumes across financial services as well as help resolve them. Consumers can now identify potential grounds for complaint in a matter of minutes and present their case in a clear and structured way.”

Focus on transparency

Reeves adds that providers should respond by focusing on transparency, clear communication and fair outcomes from the outset.

“The easier it is for customers to understand what their policy covers, how decisions are reached and what information is required, the less likely misunderstandings are to arise,” Reeves continues.

“AI also offers significant benefits for insurers. It can help organisations identify recurring customer concerns, improve service processes and ensure customers receive timely information. However, when customers are dealing with important health or financial matters, technology should support human expertise rather than replace it.

“At National Friendly, complaint volumes remain very low, which we believe reflects the importance of delivering clear communication, personal service and fair treatment throughout the customer journey.”

Putting customers at the centre

For Sharon Shier, chief customer officer and head of complaints at Western Provident Association (WPA), complaints are integral to trust and as insurers promise to pay claims when, and if, they are made, adding while price is important, insurers break that promise at their peril.

“For WPA, our culture, putting customers at the centre of all that we do, and treating others as we would expect to be treated, is integral to driving down complaints,” she continues.  

“Taking our growth into account, WPA’s complaints are down from 2025. 

“Our obsession with reducing complaints is further underpinned by our externally audited International Standards accreditations. As a result, WPA has an enviable complaints history which, I believe, is driven by our clarity, transparency, analytics and training.  

“For WPA, complaints are a feedback loop to improve processes and communications.”

Publishing complaints history

Shier further points out that WPA has for many years published its complaints history, which reveal ombudsman adjudications against it have reduced.

“There are internal and external measures,” Shier says. “When a customer claims, we ask them to score us for service and outcome and in the last 12 months we have consistently scored 4.75 out of 5 and every score under 3 results in a call to the customer to understand more.  

“WPA have led the Which? survey for medical insurance for the last four years significantly ahead of our nearest competitor and are the Which? recommended provider of medical insurance. 

“We have, for as long as I can remember, led the UK health insurance industry on the independent Trustpilot review site.”

Monthly meetings

This is further supported, Shier reveals, by two weekly leadership and manager online meetings to take the pulse of the business.  

“Monthly, we get together ‘face-to-face’ to go through all complaints with all insights and learnings actioned,” she continues.  

“The result being a reduction in the number of complaints that we uphold for the customer before escalation to the ombudsman.

“I don’t believe that, for WPA, AI is increasing complaints because whatever technology is used to help customers access their policy or how we look after customers, humans remain responsible for the result. 

“Used in the right way, the AI analytics opportunities help us better understand complaints putting downward pressure on the number of complaints.”

Continuous improvement

For Axa Health, the emphasis is on continuous improvement by thoroughly reviewing complaints to establish the root cause and exploring where changes can be made to processes and policies to prevent future issues.

Dan Eddie, customer operations director at Axa Health, tells Health & Protection: “We have robust insight and governance to ensure we’re identifying precisely where things have gone wrong and we consistently gather customer feedback through our Voice of the Customer programme. 

“Our approach is to treat complaints as an opportunity to improve and is centred on listening to our members, fixing issues promptly and learning from every situation to enhance future experiences for our members.”

Bringing benefits

And AI does bring benefits in tackling grievances, according to Eddie.

“We see AI as a helpful tool to enhance customer outcomes in private medical insurance,” he continues. 

“AI offers tangible benefits in the way members interact with our services and it helps us to provide a much more customer-centric approach. Our focus is on how AI can augment human service rather than replace it. 

“For example, the automation of routine processes helps reduce human error and speeds up service delivery – such as automating note-taking, allowing our teams to fully focus on meaningful interactions with members. AI also improves call routing, ensuring members are connected directly to the right expert without unnecessary delays. 

“Overall, we believe that AI, when used thoughtfully, can drive down complaints by streamlining processes, enhancing accuracy and enabling a more responsive and empathetic service. At Axa Health, the integration of AI is designed to complement the care and empathy that our teams bring, ultimately contributing to an improved customer experience.”

 

People remain central

James Shattock, managing director of protection and retail retirement at Legal & General, stresses that while technology is helping make the protection journey faster, simpler and more transparent, people remain central to delivering good customer outcomes. 

“The claims process is now fully digitised across retail protection, giving customers and their loved ones 24/7 access to support and reducing average claim times by almost two weeks,” he adds.

“Our AI-powered customer service platform, developed in collaboration with Microsoft, is also helping transform how we support customers. 

“By bringing customer information, previous interactions and guidance together in one place, the platform allows colleagues to respond to enquiries more quickly, resolve queries efficiently and deliver personalised support. 

“In a people-led sector like protection, the most meaningful innovations are those that combine technology with human expertise and empathy to meet evolving customer needs.”

It’s not AI versus human service

Matthew Dijkstra, chief customer officer at Vitality, points out every complaint it receives undergoes root cause analysis to ensure the provider can understand and then address underlying issues rather than simply resolving individual cases. 

But he maintains automation does not have to come at the expense of customer service. 

“In fact, when implemented effectively, AI has the potential to improve both operational efficiency and customer outcomes,” he continues. “The key is using technology to simplify processes and support customers and colleagues, rather than replacing human expertise.

“The future is not AI versus human service. It’s about combining the efficiency and insight of technology with the empathy and expertise of people. Providers that strike that balance will be best placed to improve customer outcomes, enhance service quality and reduce complaints over time.”

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