HIPAA for digital health & health-tech companies
You're a business associate with enterprise customers asking for attestations. Here's how health-tech navigates HIPAA plus everything customers pile on top.
Your reality
You're a business associate under HIPAA — directly liable, auditable by OCR. Your customers (providers, payers) demand BAAs, security questionnaires, and increasingly SOC 2 reports and HITRUST certification. HIPAA is the floor; the sales cycle sets the ceiling.
The health-tech playbook
- Treat HIPAA as table stakes, not the deliverable. Risk analysis, safeguards, BAAs with your own subprocessors — done, documented, current.
- Map the customer ask. List what your top 10 prospects require: SOC 2? HITRUST? Pen test? Build one control baseline that evidences all of them.
- Sequence: HIPAA program → SOC 2 → HITRUST. Each layer reuses the last one's evidence. Don't buy them in reverse.
- Productize the BAA chain. Know every subprocessor touching customer PHI, with BAAs and a public subprocessor list — enterprise security reviews ask immediately.
- Hire multi-framework assessors. A-LIGN, Coalfire, and Sensiba cover HIPAA alongside the commercial frameworks your customers require.
The BAA chain trap
Your customers sign BAAs with you; you need BAAs with every subprocessor touching their PHI — cloud hosting, analytics, support tooling, email. Map the full chain before your biggest prospect's security review does it for you.
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