The big imaging brokers deliver under Safe Harbor; Expert Determination is a platform badge or an option, not the default
Segmed holds a platform-level Expert Determination yet applies Safe Harbor to every delivery; OneMedNet uses Safe Harbor as the baseline and offers Expert Determination when a use case needs it; Tempus's licence agreements describe the licensed view as data without the 18 Safe Harbor identifiers. Only some sellers deliver under Expert Determination (Bridge Health Syndicate's dental imaging), and Truveta, Protege and Gradient Health do not name a method on their open pages. Datavant sells the Expert Determination itself as a service to holders.
Dated 27 Oct 2026Source checked 27 Oct 2026Basis: strong
“This certification is applied at the platform level and not on a per-dataset basis. For all data deliveries, Segmed applies the HIPAA Safe Harbor de-identification method to remove PHI identifiers prior to delivery.”
Segmed, Foundation Models page, FAQ, checked 27 Oct 2026
OneMedNet home page, Privacy by construction, checked 27 Oct 2026
Tempus AI, S-1/A Exhibit 10.15, Master Agreement with Pathos AI, checked 12 Feb 2024
Datarade, BHS dental imaging listing, checked 27 Oct 2026
- Segmed holds an Expert Determination certification at platform level (three determinations in January 2026, by Brad Malin, covering structured clinical data, imaging pixels and radiology text) but applies the HIPAA Safe Harbor method to every data delivery; its Openda licence terms state Safe Harbor, prohibit re-identification and require Segmed's written consent to redistribute raw data.
- OneMedNet uses HIPAA Safe Harbor as its baseline and offers Expert Determination only when a use case needs it, de-identifying at the source across headers, free text and burned-in pixels; to providers it offers $0 upfront and a direct revenue share whenever their data is licensed.
- An announced health-data contract total is a ceiling paid over deliveries, not money received
- Subscription to Tempus Lens, the software through which a licensee searches and selects Tempus's de-identified clinical and molecular records before licensing them (Pathos AI, four annual invoices)
- Tempus's licence agreements describe the records a licensee sees in Lens as health information without the 18 identifiers of the HIPAA Safe Harbor method; its 10-K says it de-identifies after abstraction as a covered entity or business associate. Its public policy page could not be read when checked (the site refused automated reading).
- Bridge Health Syndicate de-identifies all its dental imaging (bitewings, periapicals, panoramic, CBCT, intraoral photos and 3D scans) under HIPAA Expert Determination, under business associate agreements with its member dental organisations, and prices per project.
It is shown on its own, not counted into a figure.