Clarification on BAA Structure in Agency Model for HIPAA Compliance
We operate our own software platform that is used by multiple healthcare clinics. As an agency, we’re currently working to implement AI Voice-Agent capabilities for these clinics, and VAPI is one of the platforms we’re integrating on the backend. Our clients (clinics) only interact with our platform directly—they do not engage with or manage any third-party services we use, including VAPI.
We plan to enable HIPAA compliance at the main account level and/or per assistant, depending on the setup. I wanted to confirm how the Business Associate Agreement (BAA) should work in this agency model to ensure proper HIPAA coverage.
Here’s our current understanding:
VAPI acts as a Business Associate (BA) to our company (the agency).
Our company then acts as a BA to our healthcare clients (the Covered Entities under HIPAA).
We pay a single HIPAA enablement fee to VAPI, which—based on our understanding—would cover all sub-accounts (assistants) under our agency account.
Question:
Would this structure—one BAA between VAPI and our company, and a separate BAA between our company and each clinic—be sufficient to meet HIPAA requirements?
We’d appreciate your confirmation on this or any guidance you can provide from your legal/compliance team.
We plan to enable HIPAA compliance at the main account level and/or per assistant, depending on the setup. I wanted to confirm how the Business Associate Agreement (BAA) should work in this agency model to ensure proper HIPAA coverage.
Here’s our current understanding:
VAPI acts as a Business Associate (BA) to our company (the agency).
Our company then acts as a BA to our healthcare clients (the Covered Entities under HIPAA).
We pay a single HIPAA enablement fee to VAPI, which—based on our understanding—would cover all sub-accounts (assistants) under our agency account.
Question:
Would this structure—one BAA between VAPI and our company, and a separate BAA between our company and each clinic—be sufficient to meet HIPAA requirements?
We’d appreciate your confirmation on this or any guidance you can provide from your legal/compliance team.