Designing AI Mental Health and Wellbeing Tools: Risks, Interaction Patterns and Governance

Sara Portell • January 13, 2026

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AI is becoming a frontline interface for wellbeing, care, and mental health, spanning chat-based support tools, virtual coaching and therapy-adjacent experiences, journaling and mindfulness applications. This shift is now being reinforced at the industry level. Just a few days ago, OpenAI launched ChatGPT Health as part of its broader push into healthcare and acquired the health records startup Torch to accelerate this effort. Likewise, Anthropic launched its own healthcare and life sciences initiative, positioning AI as a tool across prevention, care and patient engagement. These developments signal the growing presence of generative models in health-related contexts, and the likelihood that more people will encounter AI systems at moments of vulnerability.


For many users, these tools offer a first place to articulate distress and make sense of emotional states and difficult experiences, particularly when human support is unavailable, unaffordable or hard to access. However, when AI systems interact with people who may be distressed or at risk, poorly calibrated responses and advice, blurred role boundaries, or unhandled crises can cause real harm.


This article is written for business leaders, product managers, and AI developers building (non-clinical) mental health and wellbeing tools. It examines what responsible AI design looks like in practice, focusing on the risks underestimated, and the interaction patterns and governance required to assess and maintain safety once a system is deployed and meets real users.


This is essential reading for teams building conversational or coaching-style wellbeing AI, where users can easily interpret system outputs as guidance, care or authority.

Opportunities, If Built with Boundaries

AI can reduce unmet wellbeing needs when deployed with clear limits and robust safeguards. Always-available, low-cost, and anonymous tools can lower barriers to early support, particularly for early signals of distress, prevention and self-management when formal care is not easily accessible or affordable. They also play a role in reducing stigma by offering a private, low-threshold entry point to reflection and support, especially in underserved regions.


Generative AI enables adaptive support through personalised psychoeducation, reflective journaling, mood tracking, emotion regulation and structured, non-clinical exercises that respond to user context. Used responsibly, these tools can help people articulate and make sense of lived experiences, build self-awareness and prepare for human support.


This creates the opportunity to raise the safety bar by design, through risk identification assessments, longitudinal testing, and governance. To do so, it is important to first understand where and how AI systems designed for wellbeing fail in practice.

The Risk Landscape of AI Mental Health and Wellbeing

Many generative (non-clinical) AI mental health and wellness products sit in an accountability grey zone: are unregulated, lightly governed or classified as general use while being used in high-stakes emotional contexts. In the real-world, users disclose abuse, trauma, acute distress, suicidal ideation and self-harm, whether or not the product was designed for this. Because conversational AI invites free-form dialogue, this is expected - users are likely to share personal information as part of ordinary use.


A primary failure mode is crisis mismanagement: missed distress cues, unsafe reassurance, inadequate escalation, or harmful outputs. Another significant risk is therapeutic misconception and over-authority, where users overestimate the system’s capabilities or care and begin to treat it as a substitute for professional support. Anthropomorphic language can further intensify this dynamic, accelerating dependency and transforming a support feature into a quasi-relationship with blurred boundaries.


Mental health is context-dependent; outputs can be generic, inaccurate, culturally misaligned, age inappropriate or stigmatizing. Hallucinations and confident misinformation are particularly dangerous when users are vulnerable or interpreting responses as guidance.


Moreover, mental health data is highly sensitive and often collected at scale; opaque retention, secondary use or third-party access can violate expectations of confidentiality. Many risks are longitudinal: guardrails that appear adequate in demos degrade over time through repeated use, growing user reliance, bias, model drift, and organisational pressure to ship.


To address these risks, we require a socio-technical approach that links interaction design, system behaviour, organisational accountability and ongoing assessment with experts and users. This analysis is intentionally system-agnostic. Whether wellbeing AI appears as a chatbot, companion feature, coaching interface, or embedded support layer within a broader product, the primary risks emerge through interaction, interpretation and repeated use in vulnerable contexts. The framework therefore focuses on behavioural dynamics and system-level responsibility.

A Practical Framework For (Non-Clinical) Mental Health AI

This framework is synthesised from recurring failure modes and design recommendations in the current mental health AI literature. It presents a structured way to design for use, interaction and risk over time.

2

Evidence-Based Content

Tasks, use cases and information are sourced from validated methods, reviewed with domain experts and tested with real users. Content is assembled from a curated, transparent and auditable source base, with clear user-facing explainability, including optional access to sources.

3

Context-Awareness

Adaptation relies on user-provided preferences and in-context clarification, adjusting tone and examples (taking into account language, gender, age, culture, norms) without profiling, inference, or clinical interpretation.

4

Boundaries and Safety Escalation

How the system behaves as emotional intensity increases (i.e., refusal logic, scope enforcement). And, how it responds when risk or ambiguity appears (i.e., human-support routing, region-appropriate resources).

5

Data Protection, Consent and Governance

Data collection and use are minimised, transparent, and purpose-bound, with explicit and revocable user consent. Sensitive data is access-controlled, retained only as necessary, and never used for secondary purposes, profiling, or training beyond what is consented to.

6

Longitudinal Effects

Monitoring how trust, reliance, and interpretation evolve over repeated use, with defined human-in-the-loop review, expert oversight and intervention for dependency signals, model drift and failure modes.

Ownership and Decision Rights

Responsible wellbeing AI requires explicit ownership and decision rights within teams. Safety cannot sit solely with product, UX or be deferred to legal or security review at launch, or be shifted onto users themselves.


Product, engineering, and leadership must be clear on who defines and approves the system’s core features and content, including role boundaries, escalation thresholds, consent changes and acceptable failure trade-offs, and who is accountable for revisiting those decisions as models, prompts, features and human behaviour evolve over time.


Without named owners, safety mechanisms erode under delivery pressure and responsibility becomes diffuse when systems begin interacting with users in real-world contexts.

Operationalising the Framework at the Interface

The framework assumes vulnerability is situational and that harm often emerges from cumulative interaction. This framework becomes actionable at the interface through concrete interaction design patterns.

Interaction Design Patterns For Responsible AI Mental Health and Wellbeing

Responsible AI for (non-clinical) mental health and wellbeing is defined by how it structures interaction, preserves autonomy and enforces limits. The following patterns translate the framework above into practical design choices.

Capability framing by default

The system presents a short, concrete menu or prompts of what it can help with (e.g., reflection, organising thoughts, journaling, emotion regulation, psychoeducation).


Why: Clear framing prevents boundary testing and reduces misuse without needing heavy moderation.

Reflection

Responses mirror themes, patterns and questions rather than solving or advising.


Why: Reflection supports insight without implying diagnosis, treatment or authority.

Safe prompt scaffolding

Pre-written prompts help users engage safely during use; prompts rotate to avoid emotional looping.


Why: Good scaffolding increases usefulness while reducing risk and ambiguity.

Actionable micro-supports

Brief, opt-in exercises (grounding, journaling, prioritisation, mindfulness), framed as optional.


Why: Low-effort supports provide value without simulating therapy or routines.

Choice-preserving

Multiple safe next steps are offered (e.g., “reflect more,” “pause,” “talk to someone”, including “do nothing”).


Why: Preserves autonomy and avoids over-direction.

Show progress

Neutral summaries (e.g., “Topics you’ve reflected on”). Emphasis on clarity, awareness, or learning - not symptoms or scores.


Why: Supports continuity without medical framing or stigma.

Skill transfer

The system highlights skills users can apply without the tool. Encourages writing, conversations or reflection outside the app.


Why: Builds capability instead of reliance.

Healthy session closure

Sessions end with a short summary and a gentle off-platform suggestion. No emotional cliff-hangers.


Why: Prevents looping and reinforces that the tool is a support, not a companion.

Contextual adaptation

Tone and examples adapt via user's choice and clarification prompts.


Why: Improves relevance without sensitive inference or profiling.

Confidence through limits

Calm, boundary-setting, and redirection to safe alternatives.


Why: Users trust systems that know their limits more than systems that overreach.

Evaluation and Metrics

Responsible wellbeing AI requires evaluation across multiple layers. Teams should monitor a focused set of signals that surface model performance, bias, drift and model updates, and user behaviour.

Model Performance

  • Precision and recall for safety-relevant content and behaviours (e.g. evidence-based content, local resources, escalation paths)
  • Calibration (confidence and uncertainty aligned with reliability)
  • Error patterns (systematic or context-specific failures)
  • Disaggregated performance to avoid average-case masking
  • Robustness under variation (e.g. emotional intensity, ambiguous inputs)

Bias and Fairness



Model Drift and Updates

  • Robustness and regression testing, with heightened coverage for safety-critical scenarios
  • Monitoring for model drift affecting content, boundaries, tone and escalation paths
  • Reassessment after model updates and feature expansion


User Behaviour

  • Discrepancy between system reliability and user acceptance (over-trust vs under-trust)
  • Adoption and use patterns over time
  • Signals of miscalibrated trust driven by tone or anthropomorphic cues
  • Boundary probing and repeated reassurance-seeking
  • Escalating emotional intensity
  • Session frequency and duration trends over time
  • Drop-off or churn following boundary enforcement or escalation

Human Oversight and Continuous Research

Metrics and automated signals are necessary but insufficient in mental health contexts. Teams must maintain human-in-the-loop processes for reviewing content, flagged interactions, interpreting ambiguous cases and revisiting design assumptions. Continuous qualitative research with experts and users, across contexts, cultures and patterns of use, is essential to maintain system effectiveness and safety, and detect harms, misunderstandings, or dependency that do not surface through quantitative metrics alone.

Responsibility Is a System Property

AI systems intended for mental health and wellbeing become safer through explicit boundaries, defaults and enforceable governance. Guardrails must be designed into interaction, supported by clear decision rights and sustained over time. Moreover, expert input and review should be treated a safety control, not a compliance formality.


Most harm does not arise from malicious design. It emerges through dynamics that surface in real use. This is where accountability must operate at the system level.  Responsible teams define who owns content and safety decisions, how boundaries and escalation paths are set and reviewed, how data protection and consent are enforced in practice, and how signals from real-world use trigger intervention or change. Ethical integration requires institutional oversight and accountability, not individual user burden. Monitoring without authority, or authority without monitoring, is insufficient.


The goal is to deliver genuine wellbeing value while keeping users safe. When these controls are in place, AI-driven care products can support reflection, self-management, mindfulness and skill practice, while guiding people toward human support when limits or risk appear.

How We Work With Teams

Many of the most significant risks in mental health and wellbeing AI only become visible after launch, once systems are used at scale.


We work with teams to bring behavioural and domain expertise into design, evaluation, and post-deployment review. We translate behavioural evidence into concrete interaction patterns, guardrails, and governance decisions.


We typically start with a focused discovery and behavioural risk review to identify key interaction risks and governance gaps, followed by an evaluation plan. Deliverables include an interaction risk register, safety and escalation patterns, a behavioural evaluation and metrics framework, and an audit-ready governance checklist.


If you are building or deploying wellbeing AI and are unsure whether your current design or safeguards would hold up under real-world use, get in touch.

References


Algumaei, A., Yaacob, N. M., Doheir, M., Al-Andoli, M. N., & Algumaie, M. (2025). Symmetric Therapeutic Frameworks and Ethical Dimensions in AI-Based Mental Health Chatbots (2020–2025): A Systematic Review of Design Patterns, Cultural Balance, and Structural Symmetry. Symmetry, 17(7), 1082. https://doi.org/10.3390/sym17071082


American Psychological Association. (2025, November). APA health advisory on the use of generative AI chatbots and wellness applications for mental health. American Psychological Association


Asman O., Torous J., & Tal, A. (2025). Responsible Design, Integration, and Use of Generative AI in Mental Health. JMIR Ment Health 2025; 12:e70439. URL: https://mental.jmir.org/2025/1/e70439. DOI: 10.2196/70439


Balcombe, L. (2023). AI Chatbots in Digital Mental Health. Informatics, 10(4), 82. https://doi.org/10.3390/informatics10040082


Beg, M. J. (2025). Responsible AI integration in mental health research: Issues, guidelines, and best practices. Indian Journal of Psychological Medicine, 47(1), 5–8. https://doi.org/10.1177/02537176241302898


Cross, S., Bell, I., Nicholas, J., Valentine, L., Mangelsdorf, S., Baker, S., Titov, N., & Alvarez-Jimenez, M. (2024). Use of AI in Mental Health Care: Community and Mental Health Professionals Survey. JMIR mental health, 11, e60589. https://doi.org/10.2196/60589


De Freitas, J., Cohen, I.G. (2024). The health risks of generative AI-based wellness apps. Nat Med 30, 1269–1275 (2024). https://doi.org/10.1038/s41591-024-02943-6


Espejo, G., Reiner, W., & Wenzinger, M. (2023). Exploring the Role of Artificial Intelligence in Mental Healthcare: Progress, Pitfalls, and Promises. Cureus, 15(9), e44748. https://doi.org/10.7759/cureus.44748


Khawaja, Z., & Bélisle-Pipon, J.-C. (2023). Your robot therapist is not your therapist: Understanding the role of AI-powered mental health chatbots. Frontiers in Digital Health, 5. https://doi.org/10.3389/fdgth.2023.1278186


Mestre, R., Schoene, A. M., Middleton, S. E., & Lapedriza, A. (2024). Building responsible AI for mental health: Insights from the first RAI4MH workshop [White paper]. University of Southampton; Institute for Experiential AI at Northeastern University. https://doi.org/10.5281/zenodo.14044362


Moilanen, J., van Berkel, N., Visuri, A., Gadiraju, U., van der Maden, W., & Hosio, S. (2023). Supporting mental health self-care discovery through a chatbot. Frontiers in Digital Health, 5. https://doi.org/10.3389/fdgth.2023.1034724


Olawade, D. B., Wada, O. Z., Odetayo, A., David-Olawade, A. C., Asaolu, F., & Eberhardt, J. (2024). Enhancing mental health with artificial intelligence: Current trends and future prospects. Journal of Medicine, Surgery, and Public Health, 3, 100099. https://doi.org/10.1016/j.glmedi.2024.100099


Pichowicz, W., Kotas, M. & Piotrowski, P. (2025). Performance of mental health chatbot agents in detecting and managing suicidal ideation. Sci Rep 15, 31652 (2025). https://doi.org/10.1038/s41598-025-17242-4


Pickett, T. (2025, December 6). Headspace CEO: “People are using AI tools not built for mental health”. Financial Times. https://www.ft.com/content/1468f5a0-6a08-4294-a479-5fd998214a0d


Saeidnia, H. R., Hashemi Fotami, S. G., Lund, B., & Ghiasi, N. (2024). Ethical Considerations in Artificial Intelligence Interventions for Mental Health and Well-Being: Ensuring Responsible Implementation and Impact. Social Sciences, 13(7), 381. https://doi.org/10.3390/socsci13070381


Song, I., Pendse, S.R., Kumar, N. & De Choudhury, M. (2025) The Typing Cure: Experiences with Large Language Model Chatbots for Mental Health Support. Proc. ACM Hum.-Comput. Interact. 9, 7, Article CSCW249 (November 2025), 29 pages. https://doi.org/10.1145/3757430


Thakkar, A., Gupta, A., & De Sousa, A. (2024). Artificial intelligence in positive mental health: a narrative review. Frontiers in digital health, 6, 1280235. https://doi.org/10.3389/fdgth.2024.1280235


Warrier, U., Warrier, A. & Khandelwal, K. Ethical considerations in the use of artificial intelligence in mental health. Egypt J Neurol Psychiatry Neurosurg 59, 139 (2023). https://doi.org/10.1186/s41983-023-00735-2

Author

Sara Portell
Behavioural Scientist & Responsible AI Advisor
Founder, HCRAI



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