Developers and HIPAA

Could a covered entity ever create a non-covered mobile app?

If a health care provider who is a covered entity were to create a general fitness/wellness app and silo off any collected data from their covered operations, could it be a valid hybrid entity? For instance, if a hospital creates a free meditation app but does not prescribe it as treatment, nor convey any data the app ingests back to medical professionals or EMRs, must the app still be HIPAA compliant? What are the criteria ...more »

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