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Compliance Knowledge Base · Digital Health

HIPAA for Digital Health

What HIPAA means for Digital Health organizations — and how we implement it at the architecture level.

What HIPAA Means for Digital Health

Digital health companies — startups and established vendors building consumer and enterprise healthcare applications — face HIPAA compliance requirements that often exceed their initial assumptions. Any application that creates, receives, maintains, or transmits PHI on behalf of a HIPAA-covered entity is a Business Associate and must execute BAAs with those covered entities. Consumer-facing health apps that collect health information from users — not on behalf of a covered entity — may not be HIPAA-covered, but enterprise distribution through hospital systems requires HIPAA compliance regardless.

The ONC's 2020 interoperability rules create specific HIPAA-adjacent engineering requirements for digital health: patient access to their own health data through SMART on FHIR APIs, information blocking prohibitions that require making patient data available to authorized applications, and provider directory requirements. Digital health companies that want to distribute through hospital and payer channels must implement these requirements as part of their core architecture — not as a separate integration project at the point of enterprise sale.

Key Requirements for Digital Health
01

Business Associate Agreement capability and BAA execution with covered entity partners

02

PHI handling in mobile and web applications with appropriate session management and encryption

03

SMART on FHIR application implementation for EHR-connected products

04

ONC information blocking compliance for products seeking enterprise healthcare distribution

05

HIPAA-compliant audit logging in consumer-facing applications

How The Algorithm Implements HIPAA for Digital Health

We design digital health HIPAA compliance for enterprise distribution from the start. BAA structure is addressed in the architecture phase — selecting only cloud providers and third-party services with available BAAs. PHI handling in mobile applications follows secure session management patterns with automatic timeout and cryptographic session binding. SMART on FHIR implementation follows published HL7 implementation guides. ALICE validates every commit for PHI handling anti-patterns specific to mobile and web contexts.

Digital Health Compliance Landscape
HIPAASOC 2HITRUST
Related Knowledge Base Terms
HITRUST CSFElectronic Health RecordsSOC 2FDA 21 CFR Part 11HIPAA — Full Overview →
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