PDI Med · Physician Independence Letter
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PDI Med Physician Documentation Access Letter
Physician Driven Innovations, LLC
dan@pdi-med.com
pdi-med.com
Date:
Physician Name (print and sign)
Institution / Health System
Department

To Whom It May Concern:

This letter addresses the access rights of the above-named physician to their own clinical documentation for the purpose of ABOG board certification case log collection, using PDI Med — a HIPAA-compliant clinical intelligence platform.

The physician's workflow involves copying text from clinical notes they authored within your electronic health record (EHR/EMR) system, and pasting that text into PDI Med for structured case log processing. This workflow is lawful, protected under federal regulation, and does not constitute a violation of any applicable privacy, data security, or intellectual property statute.

21st Century Cures Act (Pub. L. No. 114-255, Dec. 13, 2016)
ONC Information Blocking Final Rule — 45 CFR Part 171, effective April 5, 2021

The Information Blocking Rule prohibits actors — including healthcare providers, health IT developers, and health information networks — from engaging in practices that are likely to interfere with, prevent, or materially discourage the access, exchange, or use of electronic health information (EHI) by authorized parties. A treating physician's access to their own clinical documentation for board certification purposes constitutes a legitimate, treatment-adjacent professional use. Interference with this access may constitute information blocking under 45 CFR §171.100 et seq., which carries civil monetary penalties of up to $1,000,000 per violation (42 U.S.C. §300jj-52).
HIPAA Right of Access — 45 CFR §164.524

As the treating physician and author of these clinical notes, this individual has a legitimate access right to the electronic health information they created in the course of their professional duties. Use of this information for ABOG board certification — a federally recognized professional credential directly related to clinical practice — falls within the scope of treatment operations as defined under HIPAA (45 CFR §164.501).

Regarding intellectual property: Clinical documentation authored by a physician in the course of patient care is professional work product. While the EHR system provides a platform for documentation storage, the intellectual content of physician-authored notes does not constitute proprietary information of the health system or EHR vendor in a manner that would restrict the physician's own professional use of that content. No court in the United States has upheld a restriction preventing a treating physician from accessing and using the clinical notes they authored for legitimate professional purposes.

Regarding PDI Med's data handling: PDI Med processes pasted note text through a multi-layer de-identification pipeline before any clinical assertion leaves the physician's local environment. The operational layers are: (1) structured regex pattern matching across all 18 HIPAA Safe Harbor identifier categories; (2) named-entity recognition (NER) for residual person and location detection; (3) mandatory physician preview — the physician must explicitly review and verify all redactions before any submission proceeds; and (4) an outbound tripwire that blocks transmission if PHI signatures remain in the payload. All de-identification decisions are retained as evidence spans in a forensically auditable local audit log. This pipeline applies HIPAA Safe Harbor methodology (45 CFR §164.514(b)) systematically and verifiably to every submission. Clinical note content stored in the physician's vault is encrypted with AES-256-GCM under a physician-controlled key; the plaintext is not accessible to PDI Med systems. PDI Med operates as a Business Associate under HIPAA and executes BAAs with institutional partners upon request.

This physician's use of PDI Med is fully consistent with federal law, HIPAA regulations, and ABOG certification requirements. Any institutional policy that would prevent this physician from accessing and using their own clinical documentation for board certification purposes should be reviewed for compliance with the 21st Century Cures Act's Information Blocking provisions before enforcement.

PDI Med's legal counsel is available to respond to institutional inquiries at dan@pdi-med.com. We welcome direct engagement with compliance offices and welcome the opportunity to provide our full technical security documentation upon request.

Respectfully submitted,

Physician Signature · Date
Printed Name, Degree, Department
This letter template is provided by PDI Med (Physician Driven Innovations, LLC) for use by licensed physicians asserting their lawful access rights to their own clinical documentation. This document does not constitute legal advice. Physicians with specific legal questions regarding their institutional contracts or policies should consult qualified legal counsel. Federal citations current as of May 2026 — statutes and regulations subject to amendment. PDI Med reviews and updates this template when relevant law changes.