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Compliance

What Is a BAA? HIPAA for Therapy Practices

Business Associate Agreement explained for US psychologists — when you need one, what it covers, and how it fits into full HIPAA compliance.

Updated June 12, 2026 · 5 min read

A Business Associate Agreement (BAA) is a contract required under US HIPAA when a vendor handles protected health information (PHI) on behalf of a covered entity or their practice. If you are a US psychologist storing client names, session notes, or billing with diagnoses in cloud software, you almost certainly need a BAA with that vendor before go-live.

Who needs a BAA?

  • Private psychology and therapy practices storing PHI electronically
  • Vendors that store, transmit, or process PHI (cloud EHR, practice management, telehealth)
  • Not typically needed for pure payment processors that only handle card numbers without health context

PsycSuit signs a BAA with US HIPAA-covered practices at activation. Overview: BAA page.

What a BAA usually covers

  • Permitted uses of PHI — only for providing the service to your practice
  • Safeguards the vendor must maintain
  • Breach notification to your practice
  • Subcontractor (subprocessor) flow-down requirements
  • Return or destruction of PHI at contract end
  • Your right to audit or obtain vendor compliance information

A BAA does not make you fully compliant alone

HIPAA compliance is shared: the vendor’s BAA covers their obligations; your practice still needs policies, training, individual logins, device security, and client rights processes.

Full HIPAA checklist →

Outside the United States

UK and EU practices use a Data Processing Agreement (DPA) under GDPR instead of a HIPAA BAA. See GDPR guide for UK & EU.

FAQ

When must a therapy practice sign a BAA?
Before storing PHI in a cloud vendor that handles data on your behalf — typically at activation, not after months of live client data.

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