The governance model.
How physician oversight is structured, enforced, and audited across the HarnessHealth ecosystem. Read it as the specification. Live today: draft-until-attested gating as a working demonstration (/gate, /live), NPI-verified browser-held signing keys, signed records verifiable at /verify, a sandbox queue on ClinicalSwipe. Designed and not yet enforced: gateway-level classification of every output, the authority ceiling, the persistent production queue, and an administrator-proof audit log. Each is marked below.
Section 1: Principles
No AI output with clinical content reaches a patient without a licensed physician review. Clinical content is defined as: direct patient recommendations, medication mentions, diagnosis or differential language, care plan content, and billing code assignments.
Physician authority is tracked and has limits. Volume above a threshold that would preclude genuine review (defined as an average review time below 90 seconds per document) is designed to be flagged and blocked. Not yet enforced in the sandbox.
The reviewing physician's identity — NPI number, timestamp, review duration — is permanently attached to every attested document. This record is signed and linked to the document hash; its durability comes from anchoring on the public hashcare registry, which is what makes later alteration detectable.
The governance framework is designed to satisfy Joint Commission, OIG, and CMS oversight requirements. It is not designed for regulatory arbitrage. Where the framework does not provide coverage, that gap is disclosed.
Section 2: The Attestation Chain
Full chain of custody for a clinical document from AI generation through physician attestation to delivery.
- Document type (LMN, prior auth, care plan, SOAP)
- AI model used
- Underlying patient data reference hash
- Confidence flags for low-certainty content
- Attestation required: true/false
- Queue timestamp (UTC)
- Assigned reviewer specialty
- Estimated complexity rating
- Previous attestation history for document type
- Authority budget check: reviewer has sufficient remaining budget
- Review start timestamp
- Reviewer NPI
- Review duration (seconds)
- Decision: approved / approved with edits / rejected
- Edit diff (if any)
- Attestation token generated
- Document SHA-256 hash
- Reviewer NPI (fixed once signed)
- Timestamp (UTC, fixed once signed)
- Authority consumption decrement applied
- Audit log entry written
- Document delivered to requesting application
- Attestation token included in response
- Token available for independent verification at harnesshealth.ai/verify
Section 3: Regulatory Alignment
Compensation to reviewing physicians is a flat fee per review, the same whether they sign or decline, never a percentage and never tied to referral volume or downstream revenue. The structure is designed to reduce Anti-Kickback Statute exposure; it is a design principle, not a legal opinion about any arrangement.
No referral arrangement is created by the attestation relationship. Reviewing physicians are compensated for a specific, documentable service (document review). The compensation structure is consistent with fair market value for the time and expertise provided.
Paid per code for each 30-day period, and the amount varies by code and locality. The operating surgeon cannot bill it on their own patient inside the global period, and only one practitioner may bill a patient in a 30-day period. The attestation record documents who reviewed the data. CMS requires the tool to meet the FDA device definition; no registration is in process.
Chronic Care Management and Principal Care Management are billed by a practitioner with an active patient relationship. No enrolled billing practice exists in this ecosystem yet, so neither is offered today.
Section 4: What Is Not Covered
The following areas are not fully addressed by the current governance framework. Deploying organizations should conduct independent legal and compliance review:
- Formal HIPAA Security Risk Assessment — in process, expected Q3 2026
- Penetration test report — in schedule
- State-specific telehealth and medical practice regulations (varies by state)
- Malpractice coverage confirmation for individual reviewing physicians
- HSA/FSA eligibility determination via LMN — independent legal opinion required before scaling