Microsoft Publisher can be used in a HIPAA-compliant manner only when it is deployed under a qualifying Microsoft 365 or Office 365 business subscription that is covered by Microsoft’s HIPAA Business Associate Agreement for in-scope services, configured to meet HIPAA Security Rule safeguards, and governed by HIPAA Privacy Rule and HIPAA Minimum Necessary Rule controls that limit the creation, use, and disclosure of protected health information.
Publisher is a desktop publishing application used to create brochures, flyers, forms, and other layout-based documents. The application does not provide HIPAA compliance by itself. Compliance depends on whether documents containing protected health information are created only when permitted, whether content is limited to the minimum necessary for the purpose, and whether files are stored and transmitted through systems that enforce access controls, audit controls, and encryption. Publisher files saved to unmanaged endpoints, shared folders without role-based permissions, removable media, or personal cloud accounts can place protected health information outside the organization’s administrative and technical controls.
Publisher is commonly used alongside Microsoft 365 or Office 365 services for storage and collaboration. When Publisher files containing electronic protected health information are stored or shared through Microsoft-hosted services such as OneDrive for Business, SharePoint, or Exchange Online, the vendor’s Business Associate role and contract terms affect compliance. A HIPAA Covered Entity or Business Associate needs a HIPAA Business Associate Agreement when a vendor creates, receives, maintains, or transmits protected health information on its behalf. Microsoft’s HIPAA compliance materials state, “Office 365 provides HIPAA & HITECH assurances, BAA can be obtained online.” Microsoft is willing to sign a HIPAA Business Associate Agreement for eligible Microsoft 365 and Office 365 services, and the agreement should be in effect before using covered services to create, receive, maintain, or transmit electronic protected health information.
A compliant Publisher workflow requires administrative configuration aligned to the organization’s risk analysis and risk management process. Access must be restricted to authorized workforce members through unique user identification, strong authentication, and role-based permissions for file locations and collaboration sites. Sharing settings should limit external sharing and control link-based access to prevent uncontrolled distribution. Audit logging should be enabled and reviewed to detect inappropriate access and transmission. Encryption should protect files in transit and at rest within the selected storage and messaging services, and device management should address local copies, offline access, and the handling of printed materials.
Publisher can support regulated communications and internal documents that contain protected health information when the organization applies HIPAA Security Rule safeguards and uses Microsoft-hosted services only under an applicable HIPAA Business Associate Agreement.