Skip to main content
Checklist for practice admins

HIPAA vendor and BAA checklist

Short answer: Any vendor that handles, stores or sends patient information while doing work on your behalf needs a signed business associate agreement (BAA) before it gets access. Keep a list of those vendors, check each BAA is signed and current, and review what access each one has at least once a year.

Who usually needs a BAA

  • EHR and practice management vendors.
  • IT providers and MSPs.
  • Cloud backup, email and file sharing services.
  • Billing, coding and collections companies.
  • Answering services, transcription and patient messaging tools.
  • Shredding and records storage companies.

Who usually doesn't

  • Your bank processing ordinary payments.
  • The mail carrier or a courier who doesn't open what they carry.
  • Cleaning staff, if they don't handle records.

The checklist

  1. List every vendor that touches patient information.
  2. Confirm a signed BAA is on file for each one.
  3. Check the BAA covers breach reporting to you and what happens to data when the contract ends.
  4. Note what systems each vendor can reach, and remove access nobody uses.
  5. Ask key vendors whether they use two-step login (MFA) and how they back up your data.
  6. Review the list once a year and whenever you add or drop a vendor.
FAQ

Common questions

Our vendor says they're "HIPAA compliant." Is that enough?

No. You still need a signed BAA with them. "HIPAA compliant" is a marketing phrase, not a contract.

Who keeps the BAAs?

Usually the practice administrator or privacy officer. Keep them where you can find them in a day, because OCR and insurers may ask.

Who can help

Harborline helps outpatient medical, dental and behavioral health practices with about 5 to 100 staff. We run the HIPAA Security Rule risk analysis, do penetration testing in-house, and work alongside your IT provider until the fixes are verified. Tell us what you're facing and we'll set up a free 30-minute scoping call.

Contact us