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HIPAA obligations generally attach to covered entities and their business associates (and relevant subcontractors), not to every company that has ever emailed a doctor.

Covered entities (high level)

Health plans, health care clearinghouses, and health care providers who conduct certain electronic transactions.

Business associates

Service providers that handle ePHI for a covered entity—billing, cloud hosting, IT providers, transcription, etc.—often under a BAA.

Not legal advice. Classification depends on facts and contracts. Use counsel for determinations.

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