HIPAA Compliant
Trust & Compliance Guide

FrontDesk AI  |  HIPAA Compliance

Published Feb 2026  ยท  FrontDesk AI Team

HIPAA-Compliant AI Receptionists: What to Look For

AI receptionists handle patient names, dates of birth, insurance information, and health concerns — all Protected Health Information under HIPAA. This guide gives you the specific questions to ask, the red flags to watch for, and a pre-deployment checklist you can use with any vendor.

$1.9M
average cost of a
healthcare data breach
95%
of HIPAA violations stem from
inadequate vendor oversight
$50K
maximum per-violation fine
for HIPAA non-compliance

Why HIPAA Specifically Applies to AI Receptionists

Not every piece of software a medical practice uses is covered by HIPAA. The law applies specifically to systems that create, receive, maintain, or transmit Protected Health Information (PHI) — individually identifiable information related to a person's health condition, healthcare provision, or payment.

An AI receptionist sits squarely in HIPAA territory. When a patient calls and says "I need to book a follow-up for my glaucoma treatment" and provides their name and date of birth, that conversation contains PHI. When the AI writes intake information into your EHR, it is transmitting PHI. When call recordings are stored, they contain PHI.

This means the vendor providing your AI receptionist is a Business Associate under HIPAA — a third-party service provider that handles PHI on your behalf — and all the obligations that come with that designation apply.

Critical: If an AI vendor handles patient calls but refuses to sign a Business Associate Agreement (BAA), deploying their system in your practice creates a HIPAA violation — regardless of how good their product otherwise is. A BAA is not optional.

The 6 Core HIPAA Requirements for AI Receptionist Vendors

01

Business Associate Agreement (BAA)

The foundational legal requirement. The vendor must sign a BAA defining their obligations for handling PHI, security requirements, breach notification procedures, and subcontractor oversight. Without this, you cannot legally use their system.

02

Encryption of PHI

All PHI must be encrypted both in transit (TLS 1.2 or higher) and at rest (AES-256 or equivalent). Ask vendors to specify their encryption standards explicitly — vague answers are unacceptable.

03

Access Controls & Audit Logging

Access to PHI must be limited to authorized personnel on a minimum-necessary basis. The vendor must maintain audit logs documenting who accessed what PHI and when, available for compliance review.

04

Breach Notification Procedures

If PHI is compromised, the vendor must notify you within 60 days of discovery. Your BAA should specify notification timelines, information provided, and their obligations for investigating and containing the breach.

05

Subcontractor Oversight

AI systems rely on multiple underlying technologies — cloud hosting, speech recognition, NLP APIs, telephony. HIPAA requires that Business Associates ensure their subcontractors are also HIPAA compliant.

06

Data Retention and Disposal

The vendor must have documented policies for how long PHI is retained and how it is securely disposed of when retention periods end. Call recordings and transcripts containing PHI must be handled under these policies.

The 12 Questions to Ask Every AI Vendor Before Signing

Don't rely on a vendor's website claiming "HIPAA compliant." Ask these specific questions and insist on specific answers.

Will you sign a Business Associate Agreement? Required

Yes, without hesitation. A vendor who hedges or charges extra for a BAA is a red flag.

How is PHI encrypted in transit and at rest? Required

Specific standards: TLS 1.2+ in transit, AES-256 at rest. Vague answers are unacceptable.

Where is data stored — is it US-based? Required

PHI should be stored on US-based servers. International storage introduces complex compliance issues.

Who are your subcontractors and how do you ensure their compliance? Required

They should name subcontractors (AWS, Google Cloud, etc.) and confirm BAAs are in place with each.

How are call recordings and transcripts handled? Required

Clear policies on storage duration, access controls, and disposal. Recordings must be encrypted.

What is your breach notification process and timeline? Required

Notification within 60 days of discovery, with specific procedures for investigation and containment.

Do you maintain access audit logs? Important

Yes, with logs available for your review on request. This is a HIPAA requirement for Business Associates.

Have you undergone a third-party HIPAA security assessment? Important

SOC 2 Type II report or HIPAA-specific audit results give you independent verification of their claims.

Is your system trained on patient data? If so, how? Important

Be cautious about AI models trained on your patients' call data without explicit consent frameworks.

What happens to PHI when we terminate the contract? Important

Clear data return and deletion procedures within a specific timeframe after contract termination.

Do you have a documented disaster recovery plan? Best Practice

Recovery time and recovery point objectives that protect PHI availability.

What staff training do you provide on HIPAA compliance? Best Practice

Documented HIPAA training for all staff who may interact with PHI, with refresher schedules.

Red Flags: When to Walk Away

These are non-negotiable deal-breakers. If you encounter any of the following, end the evaluation.

Refuses to sign a BAA or claims their system is "technically HIPAA compliant" without one. This is not how HIPAA works.

Vague encryption answers — "we use industry-standard encryption" without specifying protocols often means they don't know.

PHI stored outside the US without a clear legal framework for international data handling.

No documentation of subcontractor compliance — if they use third-party AI or cloud services and can't confirm HIPAA BAAs with those providers, you're exposed.

Training AI on your patient data without explicit data processing agreements and patient consent frameworks.

No SOC 2 report or equivalent audit and an inability to explain security posture in specific terms.

Charging extra for HIPAA compliance — HIPAA compliance is a baseline requirement, not an add-on feature.

Your Practice's HIPAA Obligations When Using AI

HIPAA compliance is not solely the vendor's responsibility. Deploying an AI receptionist creates obligations for your practice as well.

Update Your Risk Analysis

Introducing a new vendor that handles PHI triggers an update to your risk analysis. Document the assessment and how identified risks are being mitigated.

Update Your Business Associate List

Every covered entity must maintain a current list of Business Associates and the BAAs in place with each. Add your AI receptionist vendor when you sign the BAA.

Staff Training

Staff who interact with the AI system — configuring it, reviewing call logs, managing escalations — should receive training on what PHI the system handles and how to use it compliantly.

Minimum Necessary Information

Configure your AI system to collect only the PHI that is actually necessary for its function. If the AI doesn't need a patient's full SSN to schedule an appointment, don't configure it to collect one.

Review Regularly

HIPAA compliance isn't a one-time checkbox. Review your vendor's compliance posture annually and whenever there is a significant change to how they process your PHI.

Pre-Deployment HIPAA Compliance Checklist

Use this checklist before going live with any AI receptionist system. Work through it with your vendor and file it with your compliance documentation.

Vendor Verification
BAA signed Must be executed before any PHI is shared with the vendor
Encryption confirmed TLS 1.2+ in transit, AES-256 at rest — confirmed in writing
US-based data storage confirmed Confirmed in writing in contract or DPA
Subcontractor BAAs confirmed With all vendors who will touch PHI
SOC 2 Type II or equivalent audit report reviewed Request the actual report, not just a summary
Breach notification procedures documented Confirm timeline and contact procedures in BAA
Data retention and disposal policy reviewed Retention duration and disposal method documented
Contract termination data handling confirmed How and when PHI is returned or destroyed
Internal Practice Steps
Risk analysis updated Include AI receptionist as new PHI handler
Business Associate list updated New vendor added with BAA execution date
Staff training completed On system use and PHI handling procedures
Minimum necessary configuration AI collects only required PHI for its function
Escalation protocols documented and tested Before go-live, not after
Annual review scheduled On calendar with specific date and owner

FrontDesk AI signs Business Associate Agreements with all practice partners as standard — before any patient call data is processed. All PHI is encrypted in transit and at rest, stored on US-based infrastructure, and subject to documented breach notification and data disposal procedures. We sign BAAs at no extra charge.

HIPAA Compliance Shouldn't Slow You Down

FrontDesk AI is fully HIPAA compliant, signs BAAs with every practice as standard, and has answered every compliance question on this page. Let us show you how easy it is to get started.

Schedule a Demo

Frequently Asked Questions

Yes, if they handle any Protected Health Information. An AI receptionist that answers patient calls — including names, appointment reasons, dates of birth, and health concerns — is handling PHI. The vendor is a Business Associate under HIPAA, and a BAA is legally required.
HIPAA violations can result in fines ranging from $100 to $50,000 per violation, with annual maximums of $1.9 million per violation category. Willful violations can result in criminal charges. A data breach also creates reputational damage that is difficult to recover from.
A BAA is a legal contract between a covered entity (your practice) and a Business Associate (the vendor handling PHI). It specifies permitted uses of PHI, security obligations, breach notification requirements, and procedures for returning or destroying PHI at contract termination. It must be in place before any PHI is shared.
Yes, but recordings containing PHI must be encrypted at rest, access must be controlled and audited, retention periods must be documented and justified, and disposal must be secure. Your vendor's BAA should address all of these points explicitly.
SOC 2 Type II is an independent audit certification verifying a vendor's security controls have been operational and effective over time (typically 6–12 months). For AI vendors handling PHI, it provides third-party evidence of security posture — much more reliable than self-reported compliance claims.
Requirements vary by state. Many states require one-party consent, while some require all-party consent. Best practice is to include a clear disclosure at the beginning of every AI-answered call. Your AI vendor should configure this disclosure for you as part of setup.

Trusted by established practices

University Retina Arlington Vein Institute Hudson Pro Orthopaedics

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