Evaluating Large Language Model Raters for German Open-Response Clinical Questions: A Physician-Annotated Benchmark Study of Agreement, Evaluator Bias, and Abstention

Background: Expert-annotated benchmarks for non-English open-response clinical questions are scarce. LLM-as-a-judge systems may scale evaluation but require validation. Objective: To introduce MedQADE, a standardized German open-response clinical benchmark with physician reference annotations, and evaluate LLM-as-a-judge alignment, self- and intra-family bias, and abstention. Methods: The benchmark contains 3,800 question-answer sets with answers from five student LLMs and annotations from 10 physicians. All 10 rated the 200-question core; two primary raters assessed each of 3,600 extension questions, with the tenth resolving disagreements. Nine LLM evaluators assessed all sets. We assessed physician reliability, student-model accuracy, evaluator alignment, bias, and abstention. Results: Physicians showed moderate-to-substantial agreement on answer correctness (unweighted mean pairwise Cohen's kappa = 0.612) but limited agreement on question difficulty (Krippendorff's alpha = 0.208 using squared numeric-score distances). Student-model accuracy was 17.8%-66.0% and generally decreased with physician-rated difficulty. Gemini 3 Flash approached the leave-one-out physician reference (kappa = 0.694 vs 0.709). Four of five models rated their own responses more favorably than out-of-family evaluators; five of six intra-family comparisons were positive. Physician abstention increased with perceived difficulty. Seven of nine LLM evaluators abstained in no more than 0.51% of evaluations; the two strongest evaluators assigned definitive labels to every response. Conclusions: Strong LLM evaluators approached physician agreement, but evaluator bias and low observed abstention warrant physician validation and further assessment of selective deferral before fully automated evaluation. These results do not establish clinical safety.