"In healthcare, an ML model is never "just a model." It's part of a data supply chain that may touch protected health information (PHI), vendors, cloud platforms, and downstream clinical workflows. HIPAA expectations don't only live in policy binders - they show up in dataset access patterns, logging defaults, experiment tracking, and incident response. HHS guidance also makes clear that de-identification reduces risk but doesn't eliminate it entirely, which matters when teams treat "de-identified" as " free to use forever. ""
"DO enforce "minimum necessary" access and data minimization in pipelines, features, and dashboards. DO choose a defensible de-identification approach (Safe Harbor or Expert Determination) and document it like you would a model card. DO treat HIPAA security as a system property: risk analysis, safeguards, and vendor controls - not a one-time review. DON'T ship PHI into tools that won't sign a Business Associate Agreement (BAA), including "convenient" SaaS analytics or LLM tooling. DON'T assume "de-identified" means "no re-identification risk" or "no governance needed," especially when joining datasets. DON'T wait to define breach playbooks until after an incident; HIPAA breach rules presume impermissible disclosure is a breach unless risk assessment supports otherwise."
"DO #1: Enforcing the HIPAA "Minimum Necessary" Standard in AI Systems HHS describes the HIPAA "minimum necessary" standard as limiting uses, disclosures, and requests for PHI to what's needed for the purpose. For AI teams, that translates into concrete engineering decisions: Use feature design as your first line of defense. If a model performs similarly"
Healthcare ML systems are embedded in data supply chains that commonly touch protected health information, vendors, cloud platforms, and clinical workflows. HIPAA expectations appear in operational signals such as dataset access patterns, logging defaults, experiment tracking, and incident response processes. De-identification reduces risk but does not eliminate re-identification potential, so teams must adopt defensible approaches (Safe Harbor or Expert Determination) and document them. Teams must enforce the HIPAA "minimum necessary" standard through feature design, data minimization, and access controls. Treat HIPAA security as a system property requiring risk analysis, vendor controls, safeguards, and pre-defined breach playbooks.
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