hipaa.systems
Guide

How to build a HIPAA compliant app

An engineering checklist for apps that handle PHI: which infrastructure you can use, the Security Rule's technical safeguards in product terms, and the places PHI leaks in most codebases.

On this page
  1. 1. Infrastructure under BAAs
  2. 2. Technical safeguards in product terms
  3. 3. Where PHI leaks
  4. 4. Backups, recovery and deletion
  5. 5. The paperwork that goes with the code
  6. Next steps
  7. FAQ

How to build a HIPAA compliant app at a glance

Building a HIPAA compliant app means meeting the Security Rule's safeguards in your product and infrastructure, not adding a badge. In practice: use only services covered by your vendors' BAAs; give every user a unique login with strong authentication; encrypt ePHI in transit and at rest where reasonable and appropriate (encryption is addressable); log access to ePHI without writing PHI into general logs; back up and test restores; and support deleting or returning customer data. Add a documented risk analysis, policies, and BAAs with covered-entity customers and qualifying vendors.

Applies whenYour app handles PHI as a covered entity or business associate
InfrastructureOnly BAA-covered services from cloud, email, AI and support vendors
Technical safeguardsAccess control, audit controls, integrity, authentication, transmission security (164.312)
EncryptionAddressable in the rule; in practice expected in transit and at rest
Often missedPHI in logs, error trackers, analytics and test environments
Not availableHIPAA certification for an app

First make sure HIPAA applies — the health app startup page covers that. If it does, the Security Rule’s safeguards become product requirements. The rule is technology-neutral and scaled to your risk; the checklist below is how most teams translate it.

1. Infrastructure under BAAs

Cloud providers’ BAAs cover named services only. Before you use a database, queue, storage bucket, email service or AI model with PHI, confirm it is on the vendor’s covered list and the BAA is signed. Compare HIPAA hosting and AI and LLM tools.

2. Technical safeguards in product terms

Security Rule (164.312) In your product
Access control — unique user IDs (required), automatic logoff, encryption (addressable) One account per person, role-based permissions, session timeouts
Audit controls (required) Record who viewed, changed or exported ePHI; keep the logs protected
Integrity Prevent and detect improper changes — validation, checksums, change history
Person or entity authentication (required) Strong sign-in; we recommend MFA for clinician and admin users
Transmission security TLS everywhere, including internal services and webhooks

See access control, audit controls and encryption.

3. Where PHI leaks

These are the places teams most often find PHI they didn’t plan for:

  • Application logs, error trackers and APM traces that capture request bodies.
  • Product analytics and session replay — see online tracking.
  • Push notifications and email subjects that show health details.
  • Support tickets, screenshots and screen-sharing tools.
  • Development, staging and test environments loaded with production data.
  • Prompts and responses sent to AI APIs outside BAA-covered endpoints.

4. Backups, recovery and deletion

The contingency plan standard requires data backup, disaster recovery and emergency-mode operation plans (164.308(a)(7)). Test restores. When a customer leaves, your BAA will require you to return or destroy their PHI where feasible (164.504(e)(2)(ii)(J)) — build export and deletion in from the start.

5. The paperwork that goes with the code

A documented risk analysis, written policies, workforce training and BAAs with customers and vendors. Customers will check these through security questionnaires.

Next steps

Frequently asked questions

Is there a HIPAA certification for apps?

No. HHS does not certify software. You show compliance through your risk analysis, safeguards, policies and BAAs; customers may also ask for SOC 2 or HITRUST reports.

Can we use real patient data in development or testing?

HIPAA doesn't forbid it, but every environment holding PHI then needs the same safeguards and BAA coverage. We recommend synthetic or de-identified data outside production.

Do mobile apps need to encrypt data on the device?

Encryption is addressable, so you decide based on your risk analysis — but lost phones are a common breach cause, and properly encrypted data is not 'unsecured PHI' for breach notification. We recommend it.