HIPAA Compliance for Endocrinology APCM Programs Checklist

Ensure all AI call center providers sign a BAA specifically covering the processing of sensitive metabolic and hormonal data.

Verify that all recordings of insulin titration discussions and A1C reviews are encrypted at rest and in transit.

Limit access to thyroid and diabetes patient records within the AI dashboard to authorized clinical personnel only.

Ensure any AI training or performance analytics use de-identified endocrine patient data to prevent PHI exposure.

Confirm the link between your EMR and the AI call system uses HL7 or FHIR standards with TLS 1.2+ encryption.

Use the AI system to capture and timestamp verbal consent for APCM services during initial outreach calls.

Maintain a clear, automated process for diabetes patients to opt-out of monthly monitoring calls at any time.

Inform metabolic patients that an AI assistant is used for routine monitoring and data collection tasks.

Cross-reference comorbidities like Diabetes and Hypertension to ensure APCM billing eligibility for the patient.

Implement two-factor identification, such as birth date confirmation, before the AI discusses A1C or TSH results.

Ensure TSH and A1C results are only shared through secure, authenticated voice or text channels to prevent unauthorized access.

Log all AI-assisted insulin titration suggestions directly into the patient's secure chart with a provider review flag.

Program the AI to recognize red-flag symptoms and route urgent low blood sugar reports to a live provider immediately.

Secure the pathway for transferring Continuous Glucose Monitor data through the AI interface to the medical record.

Protect patient-reported data regarding carbohydrate counting and exercise shared during APCM monitoring calls.

Use AI to automatically log every minute spent on diabetes management calls to meet the 20-minute APCM billing threshold.

Maintain a specific protocol for potential data breaches involving sensitive metabolic history or thyroid panels.

Conduct quarterly reviews of the AI's interaction logs to ensure HIPAA compliance in patient dialogue patterns.

Record the endocrinologist's sign-off on all AI-collected data for thyroid and diabetes panels to ensure clinical accuracy.

Align the AI system's data storage duration with state and federal medical record retention laws for endocrine care.