Terms Unconditional

EHR & Health Data Systems · EHR Vendor (Enterprise/Hospital) · Regulatory action + Private litigation

Epic Systems (corporate EHR)

Headline

Epic is the software company behind the medical records at a very large share of US hospitals, and through its Cosmos research database it pools de-identified records on about 310 million patients from roughly 2,358…

Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.

Epic is the software company behind the medical records at a very large share of US hospitals, and through its Cosmos research database it pools de-identified records on about 310 million patients from roughly 2,358 hospitals and 52,500 clinics (Epic's own figures). Patients almost never sign anything with Epic directly: Epic runs the software on behalf of their hospital or doctor, and Epic's own patient-app privacy policy says it does 'not sell or license your information' and sends medical-record questions back to the provider. Epic's market power has been challenged in two lawsuits (no final merits ruling in either was located as of Oct 2026). Texas Attorney General Ken Paxton sued Epic in Texas state court in December 2025, alleging it illegally monopolizes the records market, slows record access for non-Epic providers, and ships MyChart with default settings that limit parents' proxy access once a child turns 12; Epic calls the suit 'flawed and misguided' and says providers, not Epic, decide parental access. Separately, a federal judge in New York (S.D.N.Y., Sept. 4, 2025) let data company Particle Health's monopolization claims against Epic go forward while dismissing others. In January 2026 Epic itself sued health-data network Health Gorilla and some of its clients in federal court in California, alleging they pulled nearly 300,000 Epic-managed patient records while posing as health care providers. These are allegations; none has been decided on the merits.

  • SeveritySeverity 4 of 5, not independently verified. Epic is the software company behind the medical records at a very large share of US hospitals, and through its Cosmos research database it pools de-identified records on about 310 million patients from roughly 2,358…
  • Evidence tierUnassigned
  • Claims confirmedNo sourced claims yet
  • Last verified2026-10-15

Primary source. www.healthcaredive.com/news/texas-epic-antitrust-lawsuit-parent-access-medical-records-ken-paxton/807783/ — Unverified - heuristic first draft.

Last verified 24 days agoverified 24 days ago0180 days
Freshness. Last verified 24 days ago (2026-10-15); stale after 180 days.

Terms

Arbitration

No direct patient contract for the hospital EHR (Epic acts for the provider, typically as a HIPAA business associate). For the patient app, see the MyChart row: The Lever reported in Sept 2025 that Epic is rolling out MyChart terms with binding arbitration and a class-action waiver, with a downgraded version for patients who decline. Epic's own terms text could not be retrieved this pass.

Data sharing

Cosmos: Epic pools de-identified data from participating customers into a research dataset - Epic's Cosmos site lists 2,358 hospitals, 52.5K clinics and 310 million patients, with access available on request to health-system affiliates. Epic's site does not explain the de-identification method. Epic is a Carequality member and provides the tools its customers use to exchange records nationally; the Health Gorilla suit shows that this exchange network can be abused by parties falsely claiming a treatment purpose (alleged). Epic's patient-app privacy policy says Epic does not sell or license patient information and does not store health/fitness data sent through its apps.

Data chain: Epic Systems (corporate EHR), then EHR vendor layer.Epic Systems (corporate EHR)EHR vendor layer
Who holds your data. Data chain: Epic Systems (corporate EHR), then EHR vendor layer. See cross-cutting finding 16: THE EHR LAYER — THE COMPANY HOLDING YOUR CHART IS ONE YOU NEVER SIGNED WITH.

Fees and billing

No consumer fees; Epic is paid by providers. Antitrust allegations (Texas AG; Particle Health) concern market power over who can access patient data, not patient billing.

Contacts

Privacy contact. PrivacyInquiries@epic.com; +1 608-271-9000 (EU: EUPrivacyInquiries@epic.com)

Legal notice. Epic Systems Corporation, 1979 Milky Way, Verona, Wisconsin 53593 (headquarters address from epic.com/contact; registered agent not confirmed - the Wisconsin DFI corporate search blocked automated access)

Mailing address. Not recorded.

Written channel present
Paper trail: written. Written channel present.

Evidence

No claims have been itemized for this row yet.

Sources

SourceClaimTierStatusQuote
Company website · 2026-10-14
cosmos.epic.com/
whole rowUnassignedconfirmed“Health system affiliates can request access to this data.”
Quote basis: not recorded.
Trade press · 2024-11-27
beckershospitalreview.com/ehrs/277-million-patients-data-drives-epics-research-findings.html
whole rowUnassignedconfirmed“anonymized dataset that includes 277 million patients across 1,591 hospitals”
Quote basis: not recorded.
Company privacy policy · Website po
www.epic.com/privacypolicies/
whole rowUnassignedconfirmed“We do not sell or license your information. We do not receive or store copies of any health or fitness data that you transmit to your healthcare organizations using our mobile apps.”
Quote basis: not recorded.
Company website · 2026-10-14
www.epic.com/contact/
whole rowUnassignedconfirmed“Intergalactic Headquarters Verona Office Phone +1 608-271-9000 1979 Milky Way Verona, Wisconsin 53593”
Quote basis: not recorded.
Trade press · 2025-12-12
www.healthcaredive.com/news/texas-epic-antitrust-lawsuit-parent-access-medical-records-ken-paxton/807783/
whole rowUnassignedconfirmed“only Epic can decide which companies can compete”
Quote basis: not recorded.
Trade press · 2025-09-09
www.healthcareitnews.com/news/judge-denies-full-dismissal-particles-antitrust-case-against-epic
whole rowUnassignedconfirmed“Epic's motion is granted in part and denied in part”
Quote basis: not recorded.
News · 2026-01-13
www.statnews.com/2026/01/13/epic-health-gorilla-lawsuit-patient-records-health-data-interoperability/
whole rowUnassignedconfirmed“under the guise of being health care providers”
Quote basis: not recorded.
Investigative journalism · 2022-06-16
themarkup.org/pixel-hunt/2022/06/16/facebook-is-receiving-sensitive-medical-information-from-hospital-websites
whole rowUnassignedconfirmed“specifically recommended heightened caution around the use of custom analytics scripts”
Quote basis: not recorded.
News · 2025-09-18
www.levernews.com/mychart-rewrites-the-rules-patients-lose-their-rights/
whole rowUnassignedconfirmed“binding arbitration language and a class-action waiver”
Quote basis: not recorded.

Source vault

Link status: Candidate - not yet fetched

DocumentLast fetchPDF
Privacy policy
https://www.epic.com/privacypolicies/
Not fetched yetNOT CONFIRMED
Terms of service
No readable patient-facing terms URL confirmed (patients use the provider's portal terms; mychart.org/TermsConditions is behind a JavaScript/WAF wall)
Not fetched yetNOT CONFIRMED
Website
https://www.epic.com/
Not fetched yet—
Primary source
https://www.healthcaredive.com/news/texas-epic-antitrust-lawsuit-parent-access-medical-records-ken-paxton/807783/
Verification: Unverified - heuristic first draft
Not fetched yet—

Enforcement

ActionAmountLink
Epic Systems Corp. v. Health Gorilla, Inc. (alleged fraudulent 'treatment' record pulls via Carequality/TEFCA)
Private plaintiffs (EHR vendor and health systems), 2026
Complaint, No. 2:26-cv-00321 (C.D. Cal. filed Jan. 13, 2026); related to MDL No. 3193 (S.D. Fla.)
—proposed
In re Health Gorilla, Inc. Data Security Breach Litigation (MDL No. 3193)
Private plaintiffs (putative nationwide patient class actions), Judicial Panel on Multidistrict Litigation, 2026
JPML Transfer Order, MDL No. 3193 (Aug. 7, 2026) (centralized before Judge K. Michael Moore, S.D. Fla.)
—proposed
Particle Health Inc. v. Epic Systems Corp. (Sherman Act § 2 claims survive)
Private plaintiff (federal court), 2025
Memorandum and Order, ECF No. 42, No. 24 Civ. 7174 (NRB) (S.D.N.Y. Sept. 5, 2025) (Buchwald, J.)
—proposed
HHS-OIG / ASTP-ONC joint Information Blocking Enforcement Alert (Sept. 2025 crackdown)
HHS Office of Inspector General (OIG), HHS ASTP/ONC, CMS (provider disincentives), 2025
OIG Special Advisory Bulletin / Enforcement Alert (Sept. 4, 2025)
—proposed
State of Texas v. Epic Systems Corp. (EHR monopolization + MyChart parental proxy access)
Texas Attorney General, 2025
Plaintiff's Original Petition, No. 236-372872-25 (Tarrant Cnty. Dist. Ct., filed Dec. 10, 2025); AG press release Dec. 11, 2025
—proposed
HHS-OIG information blocking civil money penalty final rule (up to $1M per violation)
HHS Office of Inspector General (OIG), 2023
88 FR 42820 (July 3, 2023), eff. Aug. 2, 2023; RIN 0936-AA09; 42 C.F.R. Parts 1003, 1005
—proposed

Links are proposed matches, not yet reviewed.

State statute

No comprehensive state privacy statute on file for WI

Related companies

Linked to the same enforcement action