Why Hush is not an ambient scribe (and what it does instead)
Ambient scribes are the most talked-about AI products in general practice, and for good reason. Tools such as Heidi, TORTUS and Accurx Scribe listen to the consultation and produce a draft clinical note before the patient has reached reception. For many clinicians that is a genuine, daily time saving.
Hush is not one of them. That is a deliberate decision, not a gap in the roadmap, and we think practice managers and GP partners deserve a plain explanation of where the line sits, why we stay on our side of it, and what we give up by doing so.
Where the regulatory line sits
In April 2025, NHS England published guidance on AI-enabled ambient scribing products, developed with the MHRA and the Care Quality Commission. It draws the boundary clearly: products that solely generate transcriptions, easily verified by a qualified user, are likely not medical devices. But "the use of Generative AI for further processing, such as summarisation, would be treated as high functionality and likely would qualify as a medical device."
In practice, that means an AI scribe producing summarised clinical notes needs at least MHRA Class I medical device registration, a Digital Technology Assessment Criteria (DTAC) assessment, a supplier clinical safety case under DCB0129, and — on the practice side — DCB0160 documentation, a DPIA, and a named Clinical Safety Officer. NHS England followed up on 9 June 2025 with a communication to suppliers and NHS organisations clarifying these requirements.
To their credit, the established scribes have done that work. Heidi states it is registered as a Class I medical device with the MHRA. TORTUS holds Class I registration with a Class IIa application in progress. Accurx Scribe's underlying Tandem scribe is registered as a Class I device. That is the right and necessary posture for software that turns a consultation into a clinical note.
Which side of the line Hush is on
Hush does not listen to consultations. There is no microphone in the consulting room, no recording of the patient, and no AI-generated clinical note. What Hush does is draft documents under clinician review: referral letters, complaint responses, practice policies, patient information leaflets, appraisal preparation. You provide the facts and the judgement; Hush provides a competent first draft; a clinician reads it, edits it, and signs it. It sits on the administrative side of the boundary — the same side as your word processor, with considerably more help in it.
This is not a loophole we exploit. It is the product's intended purpose, and we hold the line in onboarding as well as in marketing. If a pilot practice starts pasting consultation recordings into Hush expecting clinical notes, we will say plainly: that is not what this tool is for, and a registered scribe would serve you better.
What we give up by staying on this side
Honesty cuts both ways, so here is the cost of our position.
We give up the scribe's headline benefit: time saved during the consultation. Hush saves time around the consultation — the letters, responses and paperwork that fill evenings — not inside it. We give up automatic entry into the clinical record: Hush works alongside EMIS and SystmOne with no integration, which means you copy and paste. We give up a place in the assurance machinery now being built around ambient voice technology, and whatever NHS funding follows it.
And we are early. We have no customers yet. Our DSPT self-assessment is in progress, not complete, and pilots run under your practice's own DPIA. We would rather tell you that than have your IG lead discover it.
What you get in exchange
A tool your information governance lead can assess as administrative software rather than a medical device deployment: no consultation audio to govern, no clinical-note generation to safety-case. A DPIA is still needed — governance is simpler here, not absent.
And you get jurisdiction. Hush runs on UK-owned NVIDIA hardware in England, operated by a UK-owned company, which places it outside the reach of the US CLOUD Act — a question of ownership, not merely of where data is stored. Your conversation history is stored encrypted on that UK hardware until you delete it, and it is never used for training.
If you want a scribe, buy a scribe
Genuinely. Registered Class I products exist; check the MHRA registration, the DCB0129 safety case and your own DPIA, and choose one. Hush can sit alongside it: the scribe handles the note, Hush handles everything else the practice has to write.
The scribe handles the note. Hush handles everything else.
Our Founding Practice pilot is free for 14 days, entirely in writing, with no card and no phone calls — capped at five concurrent practices because that is what our hardware honestly supports. Written support within one working day.
Start a written pilot →Sources:
• NHS England, Guidance on the use of AI-enabled ambient scribing products in health and care settings (27 April 2025, developed with MHRA and CQC).
• Heidi Health, Scribe Usage Policy (MHRA Class I statement).
• X-on Health help centre, Surgery Intellect compliance and regulations (TORTUS Class I; Class IIa in progress).
• Accurx help centre, Accurx Scribe: meeting NHSE requirements (Tandem Class I; NHSE 9 June 2025 communication).