tci Medicare Compliance & Reimbursement - 2016 Issue 5

Industry Note: Phone App Developers Could Be Considered Business Associates in Certain Instances

Phone apps go beyond Angry Birds and Pandora these days — and some are so advanced that they can even fall under the HIPAA privacy laws. The HHS Office of Civil Rights (OCR) released a report this week demonstrating just how a phone app can be subject to the HIPAA laws. According to the document, entitled “Health App Use Scenarios & HIPAA,” phone apps are not considered covered entities under HIPAA, but under some circumstances they could be considered “business associates,” which would require them to comply with some aspects of the HIPAA Rules. For...

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