Abstract
Security assessment of clinical AI has largely inherited the threat model of machine learning at large: adversarial perturbation of inputs, poisoning of training data, or manipulation of weights. This paper argues for a different, more tractable locus. In administrative clinical-AI pipelines, the attack surface is the set of measurable ontological distortion channels through which coded data already diverge from clinical reality, and each channel corresponds to an adversarial primitive an attacker can deliberately drive. We build the argument on a three-rung empirical substrate ladder. On synthetic data, a published adversarial cascade simulation (Synthea, n=1,000, 100 iterations) shows that a persistent low-magnitude stealth-ramp is the only configuration crossing the clinical-relevance threshold (total error 2.94 versus a 0.31 baseline), while single-shot high-magnitude injection reaches only 0.39; the exploitable surface is the feedback channel, not magnitude. On a real EHR (MIMIC-IV, 275 admissions, 4,506 rows), the distortion primitives are real, not artefacts: drift leaves 31.2% of assignments unspecified, set-membership rescue rises monotonically across comorbidity quintiles (0.44 to 0.94, Spearman ρ=0.39), and a substrate-determined false-positive floor of 25.8% survives any scoring. On routine primary-care data (23 practices, aggregate-only, non-invertible), a salient code (U07.1) carries an informativeness of 2.244 bits, the signature of salient-code overshadowing at scale. We map each channel onto a primitive from a six-class threat taxonomy, and derive a defensive corollary: because the channels are observable in non-invertible aggregates, the attack surface can be monitored without patient-level access.



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