Asurvo
Healthcare & HealthTech

HIPAA-ready GRC for companies handling patient data.

Whether you're a provider, payer, or digital health startup, Asurvo helps you operationalize HIPAA without drowning in paperwork.

Frameworks we cover

Relevant to your industry.

HIPAAHITRUSTISO 27001

Highlights

What matters for your industry.

HIPAA Security Rule mapping
BAA workflow
Breach notification tracking

Healthcare compliance

Operating a HIPAA program that holds up

Healthcare compliance starts with one question that many digital health teams answer too late: what is your role under HIPAA? A hospital, a health plan, and a SaaS vendor that stores lab results for that hospital all handle protected health information (PHI), but their obligations, contracts, and exposure differ. Settle your role and your data flows first, and the rest of the program, from risk analysis to vendor contracts, follows from it.

The regulatory map

Regime, Enforced by, Applies to, What it demands comparison
HIPAA Privacy RuleHHS Office for Civil Rights (OCR)Covered entities, and business associates to the extent of their contractsLimits on use and disclosure of PHI, minimum necessary standard, patient rights of access
HIPAA Security RuleHHS OCRCovered entities and business associates handling electronic PHIAdministrative, physical, and technical safeguards, starting with an accurate and thorough risk analysis
HIPAA Breach Notification RuleHHS OCRCovered entities and business associatesNotice to individuals, HHS, and in larger breaches the media, after a breach of unsecured PHI
HITECH Act (2009)HHS OCR; state attorneys general may also bring HIPAA actionsCovered entities and business associatesMade business associates directly liable, created the breach notification requirements, and established tiered civil penalties
FTC Health Breach Notification RuleFederal Trade CommissionVendors of personal health records and related entities not covered by HIPAA, such as many consumer health appsNotification to consumers and the FTC after a breach of identifiable health information
HITRUST CSFHITRUST (a private organization); not a lawOrganizations whose customers, often payers and health systems, request itAn assessed and certified control set that harmonizes HIPAA, ISO, NIST, and other sources

Covered entity or business associate?

Covered entities are health plans, health care clearinghouses, and providers who conduct standard electronic transactions. A business associate creates, receives, maintains, or transmits PHI on a covered entity's behalf, which describes most healthtech vendors, cloud-hosted EHR add-ons, billing firms, and analytics providers. Your own vendors that touch that PHI are subcontractor business associates, and you need agreements with them too. A consumer app collecting health data directly from users, with no covered entity relationship, may sit outside HIPAA entirely and fall under the FTC instead. The HIPAA glossary entry covers the core definitions.

Security Rule safeguards in everyday terms

  • Administrative: a documented risk analysis and risk management plan, a named security official, workforce training, sanctions for violations, contingency and disaster recovery planning, periodic evaluation, and business associate agreements.
  • Physical: facility access controls, workstation use and security rules, and device and media controls covering disposal and reuse of hardware that held ePHI.
  • Technical: unique user identification and access control, audit controls that record activity in systems holding ePHI, integrity protections, person or entity authentication, and transmission security.

Some implementation specifications are labeled addressable rather than required. Addressable does not mean optional: you must assess whether the safeguard is reasonable and appropriate, implement it or an equivalent, and document the reasoning. OCR investigations frequently cite a missing or outdated risk analysis, so treat it as a living document using a consistent risk assessment methodology. HHS also proposed significant Security Rule changes in early 2025; check the rule's current status when planning.

Business associate agreements: what to check

  • Permitted uses and disclosures of PHI are defined, and nothing broader
  • The business associate commits to Security Rule safeguards for ePHI
  • Breach and security incident reporting obligations to the covered entity, with a timeline
  • Subcontractors that handle PHI agree to the same restrictions
  • PHI is returned or destroyed at termination, or protections continue if that is infeasible
  • An inventory tracks which vendors hold PHI and whether a signed BAA is on file for each

When a breach happens

  1. Assess whether an impermissible use or disclosure is a breach. It is presumed to be unless a documented risk assessment shows a low probability that PHI was compromised.
  2. Business associates notify the covered entity without unreasonable delay and no later than 60 days after discovery.
  3. The covered entity notifies affected individuals without unreasonable delay and no later than 60 days after discovery.
  4. For a breach affecting more than 500 residents of a state or jurisdiction, notify prominent media outlets serving that area.
  5. Notify HHS: within 60 days for breaches affecting 500 or more individuals, or in an annual log submitted within 60 days of the end of the calendar year for smaller breaches.

Where HITRUST fits in the sequence

HIPAA has no official certification, so healthcare buyers look for outside assurance. Large health systems and payers frequently ask vendors for HITRUST CSF certification, and HITRUST offers assessments at increasing levels of rigor (e1, i1, and r2). A practical order is to build the HIPAA program first, add SOC 2 or ISO 27001 if broader customers ask for it, and pursue HITRUST when your target customers make it a procurement requirement. Controls built for the first programs carry forward.

Pitfalls and how Asurvo helps

  • Doing a risk analysis once for a sales cycle and never revisiting it after new systems or vendors are added.
  • Missing BAAs with the obvious vendors: the cloud host, email provider, support desk, and transcription or messaging tools.
  • Letting PHI leak into logs, analytics, and error-tracking tools that were never in scope.
  • Assuming a vendor's marketing claim of HIPAA compliance means the vendor signs BAAs for the service you use.
  • Keeping your HIPAA program in Asurvo gives you one place for Security Rule controls, a risk register with inherent and residual scoring, and a vendor inventory with tiering and questionnaires, with HITRUST CSF mapped to the same controls.

FAQ

Frequently asked questions

Is there an official HIPAA certification?

No. HHS does not certify organizations as HIPAA compliant, and no third party can issue an official HIPAA certification. Organizations demonstrate their program through documented risk analysis, policies, and evidence, and often through independent assurance such as HITRUST certification, a SOC 2 report that maps to HIPAA requirements, or an ISO 27001 certificate. Treat any HIPAA certified badge as marketing, not a regulatory status.

Do healthtech startups need a BAA with every vendor?

You need one with every vendor that creates, receives, maintains, or transmits PHI on your behalf, including cloud hosting, email, and support tools if PHI can reach them. Vendors that never touch PHI do not need one. Check that the specific product and plan you use is covered, because some vendors sign BAAs only for certain services or subscription tiers.

How often should a HIPAA risk analysis be updated?

The Security Rule does not fix a frequency, but it requires the analysis to be accurate and thorough and to be reviewed and updated as needed. In practice, organizations review it at least annually and whenever there is a significant change, such as a new system holding ePHI, a new vendor, a move to a new cloud environment, or a security incident.

Is HITRUST required for HIPAA compliance?

No. HITRUST is a private framework and certification program, not a legal requirement. It is often requested by health systems and payers as evidence that a vendor manages risk well, and its control set incorporates HIPAA requirements. Pursue it when customers require it, and build on the HIPAA controls you already have rather than starting a separate program.

Does HIPAA apply to consumer health apps?

Only if the app acts for a covered entity or business associate. Many direct-to-consumer apps that collect health information from users fall outside HIPAA. They may instead be subject to the FTC Health Breach Notification Rule, the FTC Act's prohibition on unfair or deceptive practices, and state health privacy laws. Map where the data comes from and on whose behalf you hold it.

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