Healthcare organizations should use cloud computing when the cloud service is treated as a regulated function under HIPAA and the organization executes a Business Associate Agreement, completes a documented HIPAA Security Rule risk analysis for the cloud use case, implements required administrative, physical, and technical safeguards, and verifies that the cloud service provider’s responsibilities and the customer’s configuration controls protect electronic protected health information.
Cloud computing can support clinical and operational systems that create, receive, maintain, or transmit electronic protected health information, including electronic health records, imaging platforms, analytics environments, and backups. When a cloud service provider creates, receives, maintains, or transmits electronic protected health information on behalf of a HIPAA Covered Entity or Business Associate, the provider functions as a business associate and a Business Associate Agreement is required before electronic protected health information is placed in the service.
Due diligence should focus on how electronic protected health information is stored and handled in the cloud service. Persistent storage, archiving, backup, system logging, and managed processing mean the cloud service provider is maintaining electronic protected health information even when the provider uses encryption models that limit personnel access to decrypted content. The conduit exception is limited to transmission-only functions with only temporary storage incidental to transmission, which does not match typical cloud hosting or cloud storage services.
A compliant decision depends on whether the organization can implement and enforce HIPAA Security Rule safeguards in the cloud environment. Administrative safeguards include governance over provisioning and termination of accounts, workforce training on approved cloud workflows, incident reporting procedures, and vendor management for downstream subcontractors. Technical safeguards include unique user identification, authentication controls, access controls aligned to job role, audit controls that support monitoring and investigation, integrity controls that reduce unauthorized alteration, and transmission security for data moving between users, systems, and the cloud service. Physical safeguards include device and workstation protections for endpoints that access cloud systems and controls for media disposal when local storage is used.
Policies should define permitted data types, approved services and features, and prohibited uses such as exporting electronic protected health information to personal cloud storage. The organization should document configuration baselines for identity management, encryption settings, logging, retention, backup, and remote access, and should verify that these controls remain active after platform updates and service changes.
Cloud adoption also requires operational planning for availability and recovery. Contingency planning should address backup strategy, system restoration testing, downtime access to patient information, and vendor exit procedures that support secure return or destruction of electronic protected health information at contract end.
Cloud computing is an appropriate option for healthcare organizations when contracting, technical configuration, and internal governance are aligned with HIPAA Privacy Rule limitations and HIPAA Security Rule safeguard requirements for the specific cloud use case.