Clinician-Level Agreement Without Clinical Caution: LLM Evaluator Limits in Medical AI Benchmarking

Abstract: Open-response evaluation provides stronger clinical validity than multiple-choice benchmarks but creates a scoring bottleneck that motivates automated LLM-asa-Judge approaches. Whether such evaluators replicate clinical calibration and caution, however, remains untested. We introduce MedQADE, the first standardised open-response clinical benchmark for German, a major clinical language lacking native evaluation infrastructure, comprising 3,800 items annotated by ten practising physicians and nine LLM evaluators. The top-performing evaluator model, Gemini 3 Flash, reached alignment consistent with the physician ceiling (\k{appa} = 0.694 vs. \k{appa} = 0.709), though wide confidence intervals limit interpretation. Despite this statistical alignment, automated evaluators exhibited near-absent clinical metacognition: physicians scaled abstention with item difficulty, while frontier models assigned definitive scores in every case. We additionally quantified systematic lineage-dependent biases, where models preferentially scored architectural siblings, an effect independent of language. These results show that statistical alignment does not ensure clinical caution, and that evaluator independence requires explicit verification.