Agreed, I think of a standardized clerical process (even if wholly administered by humans) as an algorithm.
I’m not a lawyer but I suspect there are regulations that apply to unjustified denial of insurance healthcare services - they don’t seem to be closely enforced and moreover there is also a frustrating magical enforcement loophole when software becomes involved where even previous precedents seem to need to be reestablished just because tech doing the denial is somehow different than people following a process.