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Richard Ferraro's avatar

Love the article Ryan, it gave me both food for thought and pause for concern. I appreciate you tagging me in this and want to address it directly and with the same consideration you took writing it.

My focus is civic technology, but there are real intersections here that I can speak to, especially around data handling and model architecture.

Legion's CTO has said publicly that they don't train their own models. It's an API-first system, they seem to prompt third-party LLMs and layer clinical data on top. So the training data is whatever those foundation models were trained on... For a system with prescriptive authority over psychiatric medication, this feels wrong to me. This should be running on closed infrastructure with models specifically trained on clinical datasets, not prompting consumer-facing APIs.

I can't easily access public information about how aggregated psychiatric adherence data, symptom patterns, or escalation trends are handled, shared, or commercialized. No disclosure on where clinical data is stored, whether interaction logs are used for fine-tuning, or what secondary use rights exist for de-identified data? And the previous company approved through this same Utah sandbox was trivially jailbroken & there's no clear indicators Legion has undergone independent adversarial testing either.

The areas I'm building in for civic tech (non-custodial architecture, on-premises data handling, air-gapped AI) could be adapted for HIPAA-compliant clinical use.

I look forward to reading more of your content and learning about how AI is being integrated into these sensitive systems. Thanks again for the engagement!

E L Frederick's avatar

The only concern I can flag is “patients must check in with a healthcare provider every 10 refills or after six months.” - how long is each refill good for? 30 days? 90 days? 120 Days?

I personally would be risk-adverse to more than a 30 days authorization. But, I am not a doctor, and don't play one on TV.

Thanks for the note.

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