What it requires
Contact data, recordings and transcripts created on behalf of a healthcare provider are PHI. A vendor processing them is a Business Associate: it must sign a BAA, apply administrative, physical and technical safeguards, use only the minimum necessary, and notify breaches without unreasonable delay (60 days at most). Its subcontractors touching PHI need downstream BAAs. One more line that matters for proactive outreach: treatment and care-coordination communications are permitted uses of PHI, but using PHI for marketing requires the patient's prior written authorization.
How we comply
We sign a BAA with every HIPAA-covered customer and maintain BAAs with every subprocessor that touches PHI — the complete chain of trust. Risk analysis and workforce training, documented. Our proactive outreach is care outreach — overdue follow-ups, pending screenings, reminders — never commercial content based on someone's condition. One honest note: “HIPAA certified” does not exist; distrust anyone promising it. What exists is this: safeguards, BAAs, and evidence.