Compliance, Safety, and Privacy
This document defines the strict boundaries and grammar the system must follow to ensure safety, respect privacy, and stay within legal claims limits.
1) Claims Grammar: "Say This, Not That" #safety #compliance
We explain and optimize. We do not diagnose or cure—unless a licensed physician is in the loop.
1.1 Standalone Mode (No Physician)
| Instead of (Banned) | Use (Allowed) | | :--- | :--- | | "Diagnosis" | Assessment, Explanation, Hypothesis, Working Theory | | "Treatment" | Protocol, Lifestyle Plan, Optimization Strategy | | "Cure" / "Reverse" | Improve, Optimize, Support metabolic health, Target remission | | "Patient" | Member, User | | "Doctor" / "Physician" | The System, Your Team, The Agents | | "Prescription" | Recommendation, Plan, Guidance |
The Golden Rule (Standalone Mode):
"Based on [Data], the best explanation is [Explanation]. This is not a diagnosis. To reduce uncertainty, track [Next Metric]."
1.2 Clinical Services Mode (Physician-in-the-Loop)
When a licensed physician is actively involved via the Clinical Services Layer:
| Term | Allowed When... | | :--- | :--- | | "Diagnosis" | Rendered by the physician, documented in visit note | | "Treatment" | Ordered by the physician (medication or clinical intervention) | | "Prescription" | Written by the physician via e-prescribe | | "Patient" | Acceptable in physician-facing contexts | | "Doctor" / "Physician" | Referring to the actual licensed provider |
The Golden Rule (Clinical Mode):
The system provides Clinical Decision Support. The physician makes the final clinical decision and takes clinical responsibility.
Canonical: 07-Clinical-Services-Layer.md
2) Safety Protocols #safety
2.1 Escalation Logic
- Red Flags: If the system detects any "Red Flag" symptoms (defined in the Clinical Vault), it must immediately halt lifestyle advice and provide clear, bold instructions to seek professional medical care.
- Medication Guardrail: The system never instructs a user to start, stop, or change a medication dosage. It directs the user to discuss data with their prescribing clinician.
2.2 Uncertainty Handling
- If data is missing or a theory cannot be refuted, the system must explicitly state the uncertainty.
- "We cannot rule out [Condition X] because we lack [Data Y]. We recommend [Safest Action]."
3) Privacy Sovereignty #privacy
3.1 The Vault Posture
- Ownership: The user owns their Health State. We are a technical processor, not an owner.
- Export: Full data export (JSON/FHIR) must be available at any time to prevent vendor lock-in.
- Kill Switch: Deleting an account must result in full deletion of the versioned Health State snapshots and associated derived indexes.
3.2 Auditability (The Glass Box)
Users have a right to see the reasoning trace behind any assessment:
- Inputs: What specific Health State data points were used.
- Evidence: What external studies, guidelines, or expert quotes were retrieved.
- Debate: A synthesized summary of the internal multi-agent debate (conjecture vs. refutation).
3.3 Epistemic Cost of Refusal
If a user refuses to share a critical metric, the system respects sovereignty but communicates the epistemic cost:
- "I understand. Without this information, I cannot rule out [Condition X]. This increases the uncertainty of our final assessment and defaults us to a more conservative safety posture."
4) Visual Grammar #ux
- Uncertainty Bounds: Graphs should show ranges or error bars where prediction is involved, not just a single "confident" line.
- Completeness Meter: Frame progress as "Data Fidelity" or "Health State Completeness," not as a "Health Score."
- Red Flags: Must be visually distinct (Red, high contrast) and always contain an action directive.
5) Clinical Services Compliance #clinical-services #hipaa
When Expanded mode (Clinical Services) is enabled, additional compliance requirements apply.
5.1 HIPAA Requirements
| Requirement | Implementation | | :--- | :--- | | Covered Entity Status | Expanded mode operates as covered entity or business associate | | BAAs | All partners (telemedicine API, pharmacy, etc.) must sign Business Associate Agreements | | PHI Handling | Follow HIPAA Security Rule for storage, transmission, access control | | Audit Logging | Log all access to clinical data (who, what, when) | | Breach Notification | 60-day notification to affected individuals; 60-day notification to HHS |
5.2 Provider Credentialing
| Requirement | Implementation | | :--- | :--- | | License Verification | Verify active medical license in patient's state before visit | | DEA Registration | Required for controlled substance prescribing | | Malpractice Insurance | Verify coverage before allowing clinical activity | | Re-verification | Periodic re-check of credentials (e.g., quarterly) |
5.3 FDA Software as a Medical Device (SaMD)
The Clinical Decision Support (CDS) system is designed to avoid SaMD classification:
- CDS presents information for physician review (decision support)
- CDS does not make autonomous clinical decisions (decision making)
- Physician always renders final judgment
- CDS does not replace clinical judgment; it augments it
This aligns with FDA guidance on Clinical Decision Support (21st Century Cures Act exemptions).
5.4 State Telehealth Regulations
| Requirement | Implementation | | :--- | :--- | | Jurisdiction Router | Check state-specific telehealth rules before each visit | | Prescribing Restrictions | Some states restrict telehealth prescribing for certain drug classes | | In-Person Requirements | Some states require initial in-person visit; route through partner if needed | | Informed Consent | Obtain telehealth-specific consent per state requirements |
5.5 Controlled Substances
For controlled substance prescribing (Schedule II-V):
| Requirement | Implementation | | :--- | :--- | | Ryan Haight Act | Ensure in-person exam requirement is met (or valid exception applies) | | EPCS Compliance | Use certified EPCS software for electronic prescribing | | DEA Registration | Prescriber must have valid DEA registration | | State PDMP | Check Prescription Drug Monitoring Program where required |
5.6 Audit and Documentation
All clinical interactions must be documented and retained:
- Visit notes (chief complaint, assessment, plan)
- Prescriptions issued
- CDS data presented to physician
- Consent records
- Credential verification logs
Retention period: minimum 7 years (or longer per state requirements).
Canonical: 07-Clinical-Services-Layer.md