HIPAA & Business Associate Statement
Effective [EFFECTIVE DATE]
1. Summary
ProviderPulse is a physician compensation modeling tool. It is designed to work with provider-level productivity and pay data, such as a provider's name, work RVU totals, compensation profile, and contract terms. It is not designed, intended, or authorized to receive or store protected health information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA).
2. Our position on business associate status
We do not act as a "business associate" under HIPAA in connection with the Service, and we do not enter into Business Associate Agreements (BAAs). Because the Service is not intended to process PHI, a BAA is neither required nor appropriate for its use as designed.
3. Your responsibility
You must not upload PHI or patient-identifying information to the Service. Before uploading any charge file, encounter file, or other document, remove patient identifiers, including but not limited to:
- patient names
- medical record numbers (MRN)
- patient account or encounter identifiers tied to an individual
- dates of service tied to an identifiable patient
- any other HIPAA identifiers
Upload only the fields needed to model compensation, such as the provider identifier, work RVU values, transaction identifiers, and the dates needed for period accounting.
4. What this means for covered entities
If you are a covered entity or a business associate of one, you remain responsible for your HIPAA obligations. Use ProviderPulse only with de-identified, provider-level data. If your workflow cannot separate provider compensation data from PHI, the Service may not be appropriate for you, and you should contact us before using it.
5. If PHI is uploaded by mistake
Uploaded files are stored as you provide them. If you believe PHI was uploaded in error, contact us promptly at [CONTACT EMAIL] so the affected files can be deleted. You remain responsible for your own breach-assessment and notification obligations.
6. Contact
[LEGAL ENTITY NAME]
[CONTACT EMAIL]
