I work with a lot of small medical offices, and they do use consumer Smart TVs in some contexts. I typically limit their network access for other reasons, and displaying X-rays isn’t something I’ve personally facilitated, but it wouldn’t shock me to discover it’s being done in other clinics, and the popularity of cloud-based ePHR software has left a lot of smaller clinics with very limited internal I.T. services.

The destination isn’t relevant, if the image leaves the clinic at all without consent, that’s a HIPAA violation. Fortunately, I think it’s more likely that the images are sampled and/or hashed in a way that means the full image isn’t technically transmitted, but considering the consequences and costs of a data breach, I’d definitely be wary of it.

The point of HIPAA is to prevent providers from colluding against you.