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What UCaaS compliance requirements apply to healthcare organizations?

Business Associate Agreement

Sign a Business Associate Agreement with the UCaaS provider before transmitting any ePHI through voice, video, voicemail, or chat. (source)

Encryption

Encrypt ePHI in transit (TLS 1.2+ for signaling, SRTP for media) and at rest using AES-256 or equivalent per HIPAA Security Rule §164.312. (source)

Access controls

Enforce unique user IDs and multi-factor authentication for every account that can access ePHI, with automatic session timeout. (source)

Audit log retention

Retain audit logs of ePHI access for a minimum of 6 years per HIPAA documentation retention requirements. (source)

Breach notification

Notify affected patients and HHS within 60 days of discovering an ePHI breach under the HITECH Breach Notification Rule. (source)

Voicemail transcription and SMS

Disable voicemail transcription and SMS for ePHI workflows unless the provider's BAA explicitly covers those subsystems. (source)

42 CFR Part 2

Apply stricter 42 CFR Part 2 consent rules when communications involve substance use disorder treatment records. (source)

Security Risk Analysis

Document a Security Risk Analysis covering the UCaaS platform and refresh it annually or after any material change.

Role-based access controls

Configure role-based access controls so clinical, billing, and admin users only see the ePHI required for their function. (source)

Compliance requirement

HIPAA

Health Insurance Portability and Accountability Act; sets US standards for safeguarding electronic protected health information.

Compliance requirement

Business Associate Agreement (BAA)

Written contract required between a covered entity and any vendor that handles ePHI on its behalf, including UCaaS providers.

Compliance requirement

ePHI

Electronic Protected Health Information — any patient-identifiable health data created, received, or transmitted electronically.

Compliance requirement

HITECH Breach Notification

Federal rule requiring notification to affected patients, HHS, and sometimes media within 60 days of an ePHI breach.

Technical dependency

Audit log

Tamper-resistant record of who accessed which ePHI, when, and from where; required for HIPAA Security Rule compliance.

Compliance requirement

42 CFR Part 2

Federal rule with stricter consent requirements than HIPAA for substance use disorder treatment records.

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