An Investigation of Memorization Risk in Healthcare Foundation Models
Sana Tonekaboni, Lena Stempfle, Adibvafa Fallahpour, Walter Gerych, Marzyeh Ghassemi
TL;DR
The paper develops a contextual, risk-based framework for auditing memorization in healthcare foundation models trained on structured EHR data. It introduces six black-box tests (T1–T6) that separately assess generative and embedding memorization (T1–T4) and patient-level privacy risk via perturbation and sub-population analyses (T5–T6), using a publicly available EHR-FM (EHRMamba2) trained on MIMIC-IV and a MedBERT-based embedding space to quantify sequence similarity with $d_{EMD}$. The results show that increasing prompt information enhances memorization signals in some cases, while embedding leakage remains weak on average; perturbation and sub-population tests reveal high-risk, patient-specific memorization in certain scenarios, underscoring the need for safeguards. The authors provide an open-source toolkit to enable reproducible privacy assessments and discuss implications for clinical deployment, emphasizing that memorization does not always equate to privacy risk but can in targeted contexts. Overall, the work offers practical methods to quantify and mitigate privacy risks in EHR foundation models prior to release and real-world use.
Abstract
Foundation models trained on large-scale de-identified electronic health records (EHRs) hold promise for clinical applications. However, their capacity to memorize patient information raises important privacy concerns. In this work, we introduce a suite of black-box evaluation tests to assess privacy-related memorization risks in foundation models trained on structured EHR data. Our framework includes methods for probing memorization at both the embedding and generative levels, and aims to distinguish between model generalization and harmful memorization in clinically relevant settings. We contextualize memorization in terms of its potential to compromise patient privacy, particularly for vulnerable subgroups. We validate our approach on a publicly available EHR foundation model and release an open-source toolkit to facilitate reproducible and collaborative privacy assessments in healthcare AI.
