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Do I need a BAA with this vendor? A four-question checker

Every vendor that handles patient information for you needs a business associate agreement before it gets the data. Most practices have more of those vendors than they think, and a few they'd never guess. Answer four questions about any vendor, then check our list of who signs.

Check a vendor

Check a vendor

1. Who is this vendor to you?
2. Does the vendor receive, store, process or have access to identifiable patient information?
3. Is the vendor's only role to move data from one place to another, without storing it beyond the transmission?
4. Is the data encrypted in a way the vendor can't read?

Answer the four questions to see whether this vendor needs a BAA.

If a vendor can reach the data, it's a business associate. Encryption without the key doesn't change that. HHS said so.Your engineer

Who signs, and who doesn't

From the vendors' own documentation, checked in October 2026. Terms change; confirm with the vendor before relying on any line.

Whether common vendors offer a HIPAA business associate agreement
VendorBAA?Condition
Microsoft 365, AzureYesIncluded by default in the Data Protection Addendum for covered entities and business associates
Google Workspace, Google CloudYesAccepted by a super admin in the Admin console; not the legacy free edition, non-admin users or consumer Gmail
AWSYesSelf-service through AWS Artifact; PHI only in HIPAA-eligible services
ZoomYesA standard BAA exists; plan eligibility isn't stated publicly, so ask
SlackYesEnterprise plan only, and not for communicating with patients
DropboxYesStandard, Business, Advanced, Business Plus and Enterprise; not consumer plans
BoxYesEnterprise, Enterprise Plus and Enterprise Advanced accounts
NotionYesEnterprise plan only
HubSpotYesEnterprise subscriptions with Sensitive Data enabled; accepted in-product
TwilioYesSecurity or Enterprise edition, HIPAA-eligible products only
DocuSignYes, by agreementDocuSign describes itself as a business associate for healthcare customers; the plan isn't stated publicly, so ask
CalendlyNoCalendly says it doesn't offer a BAA and isn't intended for PHI
MailchimpNoTerms put HIPAA suitability on you and disclaim liability; no BAA is offered on its site
StripeNoIts agreement prohibits sending it PHI
ZapierNoStates it doesn't offer a BAA
CanvaNo public BAANothing on its compliance pages; assume no

The vendors practices forget

  • The e-fax service. It stores every fax. Business associate.
  • The copier lessor, if it services the machine and can access the drive.
  • The appointment reminder and review-request platform. It has the patient list.
  • The answering service that takes after-hours calls.
  • The accountant or lawyer who sees records in the course of their work.
  • Your own subcontractors, if you're a business associate. The chain doesn't stop at you.

What goes in the agreement

HHS publishes sample provisions, and most large vendors have their own form. Either way it must cover permitted uses and disclosures, safeguards and Security Rule compliance, reporting of breaches and incidents, flow-down to subcontractors, support for patient rights, return or destruction of PHI at the end, and termination for breach. The negotiable parts are the reporting window, audit rights, insurance and indemnities. See HIPAA for business associates for the vendor's side of the table.

With AccuSights: the business associate inventory lives in the platform with the agreement, the owner and the renewal date for each vendor, reminders go out before anything lapses, and the whole list is one tab of the documentation pack when OCR or a customer asks.

Quick questions

What is a business associate agreement?
A contract required by HIPAA between a covered entity and any vendor that handles its protected health information, or between a business associate and its subcontractors. It sets out permitted uses, safeguards, breach reporting, patient rights support, subcontractor flow-down and what happens to the data at termination. The required terms are in 45 CFR 164.504(e) and 164.314(a).
Do I need a BAA with my cloud provider?
Yes. HHS's cloud guidance says a cloud service provider that stores ePHI is a business associate even if the data is encrypted and the provider holds no key. AWS, Microsoft and Google all provide BAAs; using them without one is a violation on its own.
Which vendors won't sign a BAA?
Among common tools, Calendly, Mailchimp, Stripe (which prohibits sending it PHI), Zapier and Canva don't offer one. Slack and Notion offer BAAs only on Enterprise plans; HubSpot on Enterprise with sensitive data enabled; Twilio on its Security or Enterprise editions; Box on Enterprise plans; Dropbox on Standard and above. Check the vendor's current terms before relying on this list.
Is my IT company a business associate?
Yes, if it has administrative access to systems holding patient information, runs your backups, or hosts your data, even if it never opens a record. The same applies to a managed service provider, a remote support vendor and a cloud backup service.
Do I need a BAA with another doctor's office?
No. Disclosures between covered entities for treatment don't require a BAA; both are directly bound by HIPAA. A BAA is for vendors acting on your behalf, not for other providers caring for the same patient.

Next step

Want your whole vendor list sorted and the BAAs tracked?

A business associate inventory with the agreement, owner and renewal date for each, built with your engineer. One fixed fee.

The regulator has the final say. We help interpret, scope and get you ready; we do not certify.

3-min test