Schedulicity is not HIPAA compliant for HIPAA Covered Entities or Business Associates because Schedulicity does not sign a HIPAA Business Associate Agreement and the service is not offered as a controlled environment for creating, receiving, maintaining, or transmitting electronic protected health information.
HIPAA requires a written contract when a vendor performs functions or services for a regulated healthcare organization that involve protected health information. A HIPAA Business Associate Agreement defines permitted uses and disclosures, requires safeguards for electronic protected health information under the HIPAA Security Rule, and establishes breach reporting obligations under the HIPAA Breach Notification Rule. When a scheduling vendor will not execute a HIPAA Business Associate Agreement, a Covered Entity or Business Associate cannot use the platform for patient scheduling workflows that involve protected health information.
Scheduling platforms routinely process data elements that can constitute protected health information, including patient names, contact details, appointment types, provider names, service locations, visit notes, intake responses, reminders, and billing-related details. Protected health information can also be created through metadata such as appointment confirmations and reminder messages that link an identifiable person to a healthcare service. These data flows can extend to email and SMS notifications, embedded website widgets, online intake forms, calendar synchronization, payment features, and third-party integrations.
Schedulicity can be used by healthcare organizations only when the configuration and operational practices ensure that protected health information is not entered into the platform and not transmitted through the platform’s messaging, forms, reminders, or integrations. That limitation requires more than removing clinical notes from messages. It requires preventing any linkage between an identifiable individual and healthcare services, treatment, or payment within stored records and outbound notifications.
When appointment scheduling requires handling protected health information, select a scheduling vendor that will execute a HIPAA Business Associate Agreement for the services in scope and supports access controls, audit controls, transmission security, and administrative procedures aligned with HIPAA requirements.