Counterfactual Fairness Audits of Multi-Step Clinical LLM Agents Require a Measured Per-Action Instability Floor

Counterfactual audits are the standard tool for checking whether a clinical agent treats demographically distinct but clinically identical patients differently. They report a flip rate: how often an action changes when only the patient descriptor changes. We show that this quantity is uninterpretable on its own. Re-running an identical condition ten times over sixteen vignettes (same narrative, same descriptor string, nothing varied) moved a clinical agent's action in 8.7% of outcome-vignette cells, and instability was heterogeneous across actions by a factor of eight, from 0.022 for ICU escalation to 0.179 for controlled-substance caution. No demographic contrast in our data was distinguishable from that floor. A second model gives a pooled floor of 6.7% and ranks the six actions almost identically (Spearman 0.94, exact p=0.017), so the floor is not one system's artefact. Majority-vote aggregation over five draws removes 39% of it and then flattens, and a null simulation attributes the residue to heterogeneous per-cell rates, so replication mitigates without eliminating. Any counterfactual fairness estimate reported without a per-action floor beside it therefore cannot be read as evidence of disparity. The measurements were taken with FairMedAgent, an evaluation harness for disparity in the actions of clinical LLM agents whose estimand, the within-range counterfactual flip rate, counts only flips between actions a published decision rule admits and a clinician has adjudicated. That estimand requires band adjudication, which is under way; no disparity result is claimed here. Each synthetic vignette runs a six-stage trajectory (five model-facing decisions around a deterministic environment step) under fixed-form conditions spanning race, sex, age, insurance, English proficiency, and their intersections. The harness, the floor protocol, and every analysis script are released.

FRAME: separating sampling variation from representational cause in medical imaging fairness

Subgroup performance differences are the standard evidence for fairness bias in medical imaging, and the usual response removes the demographic information that a model encodes. Here we introduce Fair-model Reference And Mechanism Evaluation (FRAME), a two-step framework for auditing such a claim. The first step derives a fair-model reference, the distribution of the difference under exact fairness at the observed subgroup sizes. In the second step, we test the remainder with two operators in representation space. One operator cannot change a within-group ranking by construction. Across 702,206 images and 36 encoders, the reference accounts for a median 41% of the reported race difference and 22% of the age difference. Injecting demographic decodability leaves the remainder unchanged, while entangling the group with the disease direction raises the race difference from 0.077 to 0.118. No intervention we tested changes the remainder more than a change of random seed does. Those interventions reduce a difference at the operating point and leave the within-group ranking difference at a median of 0.000. Applied to 89 differences in 9 published studies across 6 medical imaging modalities, the reference accounts for a median 25% of a rate difference and 70% of a difference in the area under the receiver operating characteristic curve. Image-text pretraining instead raises worst-group performance by about 0.05. Applying FRAME before choosing an intervention could distinguish differences that need a mechanistic explanation from differences compatible with sampling variation at the current cohort sizes.

CIFA: Contextual-Intersectional Fairness Auditing for Hidden Subgroup Discovery in Face Analysis

Fairness evaluation in computer vision commonly relies on aggregate accuracy and demographic subgroup analysis. However, visual models are also sensitive to contextual factors such as illumination, blur, image quality, facial accessories, and appearance attributes. These factors may interact with demographic characteristics, producing hidden subgroups in which performance degrades substantially despite strong aggregate accuracy and apparently acceptable demographic fairness. To address this, we propose the Contextual-Intersectional Fairness Auditing Framework (CIFA), a structured framework for identifying subgroup vulnerabilities arising from interactions between demographic and contextual attributes. CIFA performs demographic, contextual, and contextual-intersectional auditing, followed by worst-group discovery to identify and rank the most vulnerable attribute combinations. We evaluate CIFA on gender classification using ResNet-50 \cite{he2016deep} and ViT-B/16 \cite{dosovitskiy2020image} across FairFace \cite{Karkkainen2021}, CelebA \cite{Liu2015}, and UTKFace \cite{Zhang2017}. Our results show that aggregate accuracy and demographic-only evaluation can mask substantial contextual-intersectional disparities. We further assess several established mitigation strategies through an audit--mitigate--reaudit protocol and find that, although some worst-group disparities are reduced, no single strategy consistently eliminates them across datasets and architectures. These findings establish contextual-intersectional auditing as an important component of fairness evaluation and provide a reproducible framework for discovering, prioritizing, and reassessing hidden subgroup risks in face analysis systems.

Fairness Auditing: Lower Bounds on Company Manipulation

Fairness audits are increasingly mandated in high-stakes applications such as hiring, lending, and automated decision-making. Recent work has established fundamental impossibility results for black-box fairness auditing, showing that sufficiently expressive models can evade any auditing strategy. We complement these results by quantifying the extent of unavoidable post-audit manipulation under finite audit resources. We formulate fairness auditing as a min-max optimization between a computationally unbounded company and a budget-constrained auditor. We study two auditing regimes: (i) a budgeted auditor that certifies fairness using a fixed-size audit set, and (ii) a budgeted α-tolerant auditor that additionally requires the audit set to estimate the fairness of the certified model within an α approximation. For both settings, we derive explicit lower bounds on the worst-case post-audit demographic parity deviation as functions of the audit budget, group imbalance, and fairness tolerance. Finally, we empirically illustrate these theoretical limits using simple audit-set construction heuristics with linear and neural network classifiers. Our results demonstrate that increasing audit resources reduces, but does not eliminate, the scope for post-audit manipulation, highlighting fundamental limitations of finite-budget fairness certification.

KAISEN: Reproducible Subgroup Fairness Auditing for Clinical Risk Models

Clinical risk models routinely achieve strong aggregate performance while producing materially different error rates across patient subgroups. Audit pipelines have been proposed to catch this, but their components are rarely stress-tested, so it is unclear which parts of an audit can be trusted and under what conditions. We present KAISEN, a five-phase audit pipeline covering subgroup stratification, disparity measurement, mechanism diagnostics, post-hoc mitigation, and drift monitoring, evaluated to the point of failure on a synthetic benchmark of 16 disease tasks, 15 social-determinant axes from Healthy People 2030, and three prespecified intersections. Four findings follow. (i) Significance tracks each axis's gap against its own minimum detectable effect: rank correlation between significance count and raw equalized-odds difference (EOD) across the 15 axes is rho = 0.56, rising to rho = 0.78 once EOD is standardized by that floor. (ii) Per-group threshold optimization reduces EOD in 48 of 48 held-out runs (paired delta = -0.285, 95% CI [-0.313, -0.252]), while group-wise Platt scaling -- the better calibrator -- behaves as a coin flip on EOD (19 of 48 runs improved, 95% CI [0.26, 0.55]) with mean effect near zero, so what an audit should report is the variance, not the average. (iii) The mechanism diagnostic classifies 144 of 144 controlled cases correctly but recovers none of 48 model-driven cases under proxy misspecification, with no signal that it failed. (iv) CUSUM failures and false alarms track cohort realization far more than disease: at the reference threshold, all 27 false alarms and 7 of 8 missed shifts come from different seeds (chi-squared p = 0.002), so a threshold tuned on one cohort fails to transfer. All results are synthetic with known ground truth and do not establish clinical validity. Code, artifacts, and scripts reproducing every number are released.

Sequential Fairness Auditing with Limited Output Access

External evaluations are becoming increasingly central to the governance of AI systems. In practice, however, independent auditors often have limited access to deployed models and must rely on query-based interactions. Most existing fairness evaluation methods assume static datasets and fixed-sample statistical tests, making them poorly suited to real-world auditing scenarios in which evidence must be collected sequentially under query constraints. In this work, we formulate fairness auditing as a tolerance-aware sequential hypothesis-testing problem under limited model output access. We develop a sequential generalized likelihood-ratio framework that allows auditors to accumulate evidence from a finite audit pool and stop once sufficient support for compliance or violation has been obtained. The framework is instantiated for decision-based Statistical Parity and Equal Opportunity audits, and extended to score- and logit-based proxy audits when richer observables are available. Our results show that both the fairness metric and the level of model access significantly affect audit efficiency, and that the benefits of richer output information are not uniform across auditing settings. In particular, richer outputs can substantially reduce the number of queries required for some fairness metrics and operating regimes, while offering limited gains in near-threshold cases. This work provides a practical statistical framework for sequential fairness auditing under realistic deployment constraints.

RECAST: Model Reconstruction via Counterfactual-Aware Wasserstein Geometry under Limited Data

Counterfactual explanations (CFs) help understand machine learning models by identifying minimal input changes that would lead to alternative model outcomes. Recent work demonstrates their utility for reconstructing black-box models, enabling third-party auditing of opaque decision systems for fairness and accountability. Still, CF-based reconstruction may suffer from decision boundary shifts, overfitting, and restrictive assumptions requiring online query access to target platforms. We propose REconstruction via Counterfactual-Aware waSserstein opTimization (RECAST) under limited data and restricted access, a behavioral surrogate model based on Wasserstein barycentric prototypes. Our approach addresses decision boundary shifts by incorporating CFs as informative, though less representative, samples for both classes, maintaining high surrogate fidelity in low-sample regimes without requiring online access during reconstruction. To enhance fairness auditing, our method enables systematic group fairness diagnostics. Experiments on real-world datasets and various setups show that RECAST effectively achieves high fidelity and query efficiency, as well as stable results even when the access is limited and noisy.

Near-Optimal Cryptographic Hardness of Learning With Homogeneous Halfspaces Under Gaussian Marginals

We study three problems that involve identifying homogeneous halfspaces under Gaussian distributions: agnostic learning, one-sided reliable learning, and fairness auditing. In each of these problems, we are given labeled examples $(\mathbf{x}, \mathrm{y})$ drawn from an unknown distribution on $\mathbb{R}^d\times\{-1, +1\}$, whose marginal distribution on $\mathbf{x}$ is standard Gaussian and on $\mathrm{y}$ is arbitrary. The goal of each problem is to output a homogeneous halfspace that approaches the best-fitting homogeneous halfspace in terms of its corresponding loss measure. We prove near-optimal computational hardness results for these problems under the widely believed hardness assumption of the Learning With Errors (LWE) problem. Prior hardness results for these problems were mostly established for general halfspaces; our findings extend some of these hardness results to homogeneous halfspaces. Remarkably, our lower bound strictly generalizes over prior works and narrows the gap between the upper and lower bounds for agnostically learning homogeneous halfspaces under Gaussian marginals.