H33-74 for Healthcare

What gets attested in healthcare

Each of the following operational events emits an H33-74 proof at the moment it occurs. The collection composes into the operational history that audit, compliance, and regulatory teams reconstruct from.

• Prior authorization decisions: approval, denial, peer-to-peer review, appeal disposition.
• Clinical decisions emitted by AI clinical decision support systems.
• HIPAA disclosure events: minimum-necessary determinations, accounting-of-disclosure entries.
• Prescribing decisions: e-prescribing transmissions, controlled-substance checks, formulary overrides.
• Quality measure events: care gap closure, quality bonus determinations.
• Adverse event reports and incident classifications.
• Credentialing and privileging decisions.

Regulatory pressure that already justifies this

Healthcare is regulated under frameworks whose audit horizons now extend past the lifetime of the systems and vendors holding the evidence. H33-74 produces evidence that survives that horizon:

• HIPAA. Privacy Rule, Security Rule, Breach Notification Rule, accounting of disclosures. See: HIPAA crosswalk
• EU AI Act. High-risk AI in clinical decision support. See: EU AI Act crosswalk
• GDPR. European patient data. See: GDPR crosswalk
• SOX. Publicly listed payers and providers. See: SOX crosswalk
• CMS Meaningful Use / Promoting Interoperability. EHR audit trails.

Scenarios this changes

Hospital switches EHR vendor

Every clinical decision support output, every prior authorization, every accounting-of-disclosure entry from the prior EHR remains independently verifiable. The new EHR carries forward zero technical dependency on the prior vendor.

Office for Civil Rights requests disclosure history from five years ago

The original PQ-signed proofs of each minimum-necessary determination and accounting entry are produced. The compliance officer, the requestor, the data category, and the determination basis are all in each proof.

Payer faces RADV audit on AI-assisted risk-adjustment coding

The proof of every AI suggestion, every coder review, every supporting clinical evidence link, and every final coding decision is produced. The audit team verifies each one directly.

What survives versus what gets replaced

How to start

Three integration patterns, ordered by how invasive each is.

Pattern 1 — Receipt at the policy engine

The decision system (policy engine, approval workflow, AI scorer) emits an H33-74 proof for every decision at the moment it is made. No change to upstream systems. Auditors verify proofs directly.

Pattern 2 — Receipt at the system of record

Each system of record (treasury, claims, records, EHR) is wrapped so that committed transactions emit H33-74 proofs in addition to the existing audit log. Existing systems remain unchanged. Proofs become a parallel canonical record.

Pattern 3 — Receipt at the integration bus

Service mesh or integration bus intercepts cross-system events and emits H33-74 proofs. Highest reach, requires bus integration. Useful where systems-of-record cannot be modified.

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