HIPAA Compliance for CHF APCM Programs Checklist

Ensure all AI call center vendors have a signed Business Associate Agreement covering heart failure data processing.

Use end-to-end encryption for AI-driven phone calls regarding daily weight and diuretic adjustments.

Implement multi-factor identity verification before discussing HFrEF medication titration via phone.

Encrypt all AI-generated transcripts of fluid restriction counseling and cardiac device follow-ups.

Limit access to CHF call recordings and transcripts to authorized clinical staff and APCM care managers only.

Securely document and store patient consent for APCM services for Medicare heart failure populations in the EHR.

Ensure the 20+ minutes of non-face-to-face CHF care is logged in a HIPAA-compliant, auditable environment.

Encrypt records linking CHF to common comorbidities like CKD or COPD to maximize APCM reimbursement safely.

Maintain secure audit trails for all clinical decisions made during AI-facilitated phone triage sessions.

Securely store risk assessment data used to prioritize high-value heart failure candidates for APCM enrollment.

Ensure cellular or Bluetooth scales transmitting daily weights to the AI system use TLS 1.2 or higher encryption.

Regularly update software on cardiac device monitoring hubs to prevent unauthorized PHI access or data leaks.

Use secure, encrypted channels for notifying clinicians of sudden weight spikes or significant fluid retention.

Maintain extra sensitivity and restricted access for records involving advanced heart failure care plans.

Use secure direct messaging for sharing patient progress with external cardiac rehabilitation facilities.