HIPAA Compliance for Clinical AI

The Challenge: AI in Healthcare

Healthcare organizations adopting AI face compliance questions that traditional EHR vendors haven't addressed:

How do you log PHI access when a clinician asks AI to summarize a patient's history?
How do you enforce minimum necessary when AI retrieves information from multiple records?
How do you retain AI conversation logs that contain PHI?
How do you respond to patient access requests for AI-generated summaries?

ChatMD provides the technical controls and audit evidence your compliance officer needs.

Security Rule: Technical Safeguards

Access Controls

ChatMD implements unique user identification:

Every clinician has a unique identifier tied to their AI interactions
Organization and department-based access controls limit which patient records each clinician can query

Audit Controls

Every AI interaction with patient data is logged in a tamper-evident audit trail that captures:

Who accessed the information
What was accessed (patient record, lab result, clinical note)
When the access occurred
Context for the access (clinical query, department, care team)
Outcome of the interaction

Integrity Controls

ChatMD uses cryptographic chaining to ensure audit records cannot be altered without detection. Any modification to historical records breaks the chain and is immediately detectable, providing assurance that logs presented to auditors accurately reflect what occurred.

Transmission Security

All data transmission between clients and ChatMD is encrypted using TLS (Transport Layer Security). Cloudflare enforces TLS on all connections, supporting TLS 1.2 and 1.3.

Privacy Rule: Administrative Requirements

Minimum Necessary

ChatMD supports minimum necessary access through:

Department-based isolation — Clinicians only access records within their organization and department
Access logging — Audit trail enables review of access patterns for appropriateness

Accounting of Disclosures

When patients request an accounting of disclosures, ChatMD's audit trail provides a complete record of AI-assisted access to their information, including timestamps, clinician identifiers, and context for each access.

Data Retention

HIPAA requires retention of certain records for 6 years. ChatMD supports this through configurable retention periods, automatic archival before deletion, and legal hold capability to preserve records during investigations.

Business Associate Agreement

ChatMD operates as a Business Associate under HIPAA. Our BAA covers use and disclosure limitations for PHI, safeguards for PHI protection, breach notification requirements, and subcontractor requirements.

Contact your account representative to execute a BAA before processing PHI.

Implementation Checklist

Execute Business Associate Agreement
Configure organization-level retention policies
Set up department-level access controls
Define legal hold procedures
Train workforce on appropriate AI use
Establish audit log review schedule
Document policies in HIPAA compliance program