AI tools see a lot of protected health information: notes, diagnoses, insurance details. HIPAA applies to all of it.
Six questions to ask any billing partner using AI
- Is there a BAA with every AI vendor that touches PHI? If a tool processes PHI on someone's behalf, it is a business associate.
- What data does the tool see? Only the fields the task needs, under the minimum-necessary standard.
- Is PHI used to train models? It shouldn't be used to train public or shared models.
- Where is data stored and how is it encrypted? In transit and at rest.
- Is there an audit log? Who accessed what, and which AI outputs were accepted or rejected.
- Who reviews outputs? A credentialed person, before any submission to a payer.
Why human review is a compliance issue
Billing a code the record doesn't support is a false-claims risk regardless of whether software suggested it. Human review is how a practice shows that coding decisions follow documentation and rules.
Our approach
- BAAs in place before any PHI is accessed, including with AI vendors
- role-based, audited access inside the practice's own systems
- no use of practice data to train public models
- every AI suggestion reviewed by our credentialed coding or AR team
See HIPAA and data security for our full safeguards.
This article is general billing information, not legal or coding-compliance advice. Payer rules, CPT descriptors and federal guidance change; check the current versions for your claims.