HIPAA Compliance for APCM Programs Checklist

Ensure signed BAAs are in place with all APCM software vendors, AI call center providers, and data storage partners.

Perform a targeted HIPAA risk analysis specifically for the data workflows and transmission paths used in APCM outreach.

Train care managers and administrators on PHI handling during phone-based outreach and automated messaging protocols.

Update internal privacy policies to include specific rules for APCM data sharing, storage, and retention periods.

Review the security certifications (e.g., SOC2, HITRUST) of AI service providers to ensure they meet HITECH standards.

Verify that all PHI transmitted via APCM platforms is encrypted using AES-256 or equivalent standards at rest and in transit.

Configure Role-Based Access Control to ensure only authorized care team members can access APCM call transcripts and care plans.

Enable detailed logging of every automated call, patient interaction, and modification to care management documentation.

Store AI-generated call recordings and transcripts in a HIPAA-compliant, encrypted environment with restricted access.

Configure all APCM management dashboards to automatically log off users after a defined period of inactivity.

Document patient consent for APCM services, specifically mentioning data sharing with third-party AI and technology partners.

Program AI agents to verify at least two patient identifiers before discussing any PHI during an automated call.

Limit the PHI available to AI call scripts to only what is strictly necessary for the specific care management task.

Provide clear, automated methods for patients to opt out of APCM outreach or specific communication channels at any time.

Systematically document and honor patient preferences for voice, text, or email-based care coordination to remain compliant.

Regularly audit the accuracy of AI-generated care plan updates as they are synced back to the primary EHR system.

Include APCM-specific data breach scenarios and notification workflows in the practice’s master incident response plan.

Define and enforce strict retention and disposal schedules for APCM call logs, transcripts, and temporary care files.

Conduct quarterly reviews of APCM platform access logs to identify and investigate any unauthorized or suspicious PHI access.

If the practice serves SUD patients, implement technical filters to prevent AI processing of sensitive Part 2 data without specific consent.