When evaluating technology partners for your community, one of the most common questions is: “Is this platform HIPAA compliant?”
For senior living executives, especially those overseeing assisted living, memory care, or skilled nursing operations, this can be a confusing topic. Resident engagement platforms — tools designed to connect residents, families, and staff — don’t fit neatly into traditional healthcare technology categories.
This article breaks down what HIPAA really means, when it applies to resident engagement technology, and why vendors should not simply claim they are “HIPAA compliant.” Instead, they should be HIPAA-capable and BAA-ready — a critical distinction every senior living executive should understand.
Understanding HIPAA: Who It Applies To
The Health Insurance Portability and Accountability Act (HIPAA) was enacted to protect Protected Health Information (PHI) — any data that can identify an individual and relates to their health status, care, or payment for healthcare.
Two main groups fall under HIPAA:
- Covered Entities: Healthcare providers (e.g., hospitals, physicians, nursing homes), health plans, and clearinghouses.
- Business Associates (BAs): Vendors and partners that create, receive, maintain, or transmit PHI on behalf of a covered entity.
In senior living:
- Independent Living (IL) communities typically are not HIPAA-covered entities.
- Assisted Living (AL) and Memory Care (MC) communities are generally regulated at the state level, not directly by HIPAA. However, if they provide or coordinate healthcare services, HIPAA requirements can apply.
- Skilled Nursing Facilities (SNFs) are almost always covered entities under HIPAA.
👉 Key takeaway: Whether HIPAA applies depends on the type of community and the way the platform is used.
What Counts as PHI in Resident Engagement Platforms?
Not all resident information qualifies as PHI. For example, event calendars, menus, or general announcements are not considered health data.
But depending on platform features, some information can cross the line into PHI, such as:
- Resident name combined with level of care.
- Date of birth or address linked to care or safety.
- Geofencing alerts (e.g., notifying staff when a memory care resident leaves the property).
- Daily activity tracking that could indicate resident health status or well-being.
In short, if information is individually identifiable and tied to health or safety, it may qualify as PHI.
Why “HIPAA Compliant” Is a Misleading Claim
Many vendors in the senior living technology space proudly claim to be “HIPAA compliant.” While this sounds reassuring, it’s actually misleading — and here’s why:
- There’s no official HIPAA certification.
No government or independent body certifies a vendor as HIPAA compliant. Anyone making this claim is oversimplifying. - Compliance is contextual.
A platform may have the right technical safeguards, but if the customer never uses it for PHI, HIPAA doesn’t apply. Conversely, if a customer uses it with PHI, the vendor becomes a Business Associate — and compliance depends on a formal agreement and safeguards. - It shifts responsibility.
By saying “HIPAA compliant,” vendors imply they’ve already solved the issue. In reality, HIPAA compliance is a shared responsibility between the community and the vendor.
👉 Better language: Vendors should position themselves as HIPAA-capable and BAA-ready, not blanket “HIPAA compliant.”
Business Associate Agreements (BAAs): Why They Matter
A Business Associate Agreement (BAA) is a legal contract between a HIPAA-covered community and a vendor that handles PHI on their behalf.
The BAA spells out:
- How the vendor will use and protect PHI.
- Safeguards (technical, administrative, physical) to prevent unauthorized use or disclosure.
- How breaches will be reported.
- Responsibilities for subcontractors who may also process PHI.
Without a BAA, a HIPAA-covered community cannot legally share PHI with a vendor.
👉 For senior living executives, this means: If you expect your engagement platform to handle resident health or safety data, you must ensure the vendor is willing to sign a BAA.
How Resident Engagement Platforms Can Be HIPAA-Capable
A HIPAA-capable platform demonstrates strong security and privacy practices, including:
- Encryption of data in transit and at rest.
- Access controls to limit who can view sensitive information.
- Secure authentication, ideally through a trusted identity provider (e.g., Auth0).
- Audit logs to track access and changes to information.
- Data minimization — only collecting and storing the information necessary for the intended purpose.
- Breach notification protocols to ensure communities are informed promptly if an incident occurs.
By meeting these standards, platforms can support communities in complying with HIPAA — even if they themselves are not covered entities.
Quiltt’s Approach to HIPAA and Resident Privacy
At Quiltt, we recognize that resident engagement data sometimes touches PHI — especially in assisted living, memory care, and skilled nursing settings. Here’s how we approach it:
- HIPAA-Capable by Design
Quiltt uses industry-standard safeguards: encryption, secure authentication via Auth0, access controls, and audit logs. - BAA-Ready
If your community uses Quiltt in a way that involves PHI, we will act as a Business Associate and sign a BAA with you. - Clear Data Practices
We never sell resident personal information. We only use aggregated, anonymous data to improve the platform. Resident-generated content (photos, posts, events) is used strictly within your community’s Quiltt environment. - Transparency and Trust
We commit to notifying communities promptly in the event of a breach, providing details and guidance to mitigate impact.
What Senior Living Executives Should Look For
When a technology partner claims “HIPAA compliance,” don’t stop there. Ask these questions:
- Do you understand what information in our community might qualify as PHI?
- Will you sign a Business Associate Agreement if needed?
- What technical safeguards do you have in place (encryption, authentication, access controls)?
- How do you handle data breaches?
- Do you use or share resident content for any purpose beyond the platform?
A vendor who can answer confidently is far more valuable than one who simply says “yes” to HIPAA compliance.
Conclusion: HIPAA-Capable, Not HIPAA-Compliant
For most resident engagement use cases — calendars, menus, family communications — HIPAA doesn’t apply. But in cases where resident health or safety data is involved, HIPAA considerations do matter.
That’s why vendors shouldn’t claim blanket “HIPAA compliance.” The real standard is HIPAA-capable and BAA-ready — with the infrastructure, safeguards, and legal framework to protect residents if PHI is involved.
At Quiltt, we embrace that standard. We believe in transparency, trust, and partnership with communities. Because at the end of the day, protecting residents’ information is about more than compliance — it’s about building confidence with families, staff, and the residents we all serve.
