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Handling PHI through AI requires an unbroken chain of Business Associate Agreements — from your organization, through HASP, to every party that touches the data. This page explains how that chain is structured and what each link covers.

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The chain

You sign one BAA with HASP. It covers your organization whether you sign as a covered entity or as a business associate building your own product for covered entities: in the first case HASP acts as your Business Associate; in the second, HASP acts as your Subcontractor under 45 CFR §164.502(e)(1)(ii), and the same agreement serves as the required written subcontractor agreement. Each party contracts one link only — the BAAs between you and the covered entities you serve are yours to hold, and HASP’s inference BAA with AWS (Link 2) is HASP’s. Either way the HASP BAA is the gate for production-mode PHI usage. Without an active BAA, raw PHI never reaches a provider: a paid org is refused inference until its BAA is signed, and Free Evaluation orgs — which have no signed BAA, and whose terms prohibit PHI — have any PHI redacted before it leaves HASP (the allow PHI mode falls back to redact). HASP runs every language model through Amazon Bedrock under its Business Associate Agreement with Amazon Web Services, so prompts and outputs stay inside the AWS boundary and are never sent to Anthropic or OpenAI. Each model in the catalog declares its BAA coverage in its baa_coverage field, and every model runs on Amazon Bedrock under the AWS BAA, so the chain stays unbroken without any per-customer provider negotiation. Models that can only run under a human-review retention mode (currently Claude Fable) are not offered.

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PHI handling is HASP-owned

PHI de-identification, redaction, and re-identification is a HASP-owned core substrate capability — not a function rented from a third party. It runs as a step inside HASP’s AI Gateway pipeline, above the provider-routing layer:
The capability is built on Microsoft Presidio, extended with healthcare-specific recognizers (MRN formats, NPI numbers, drug names, lab values, ICD/CPT codes). PHI is detected before content leaves HASP’s substrate, and the organization’s PHI mode decides what happens next.
What reaches the model is governed by the organization’s PHI mode. allow (eligible organizations only) sends content containing PHI to Amazon Bedrock under the AWS BAA. redact de-identifies it in HASP’s own pipeline first — the model receives placeholder tokens ([NAME_1], [MRN_1], …), and re-identification happens on the way back, inside HASP’s substrate. block refuses the request.

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What’s covered, and what’s disclosed

  • PHI handling controls are covered by HASP’s own attestation engagement — HASP attests the controls it operates rather than inheriting attestation from a third-party gateway.
  • User feedback is never forwarded upstream. Thumbs ratings and conversation feedback are stored inside HASP’s data plane only; they are never transmitted to AWS, Anthropic, OpenAI, or any provider as training signal or telemetry.
  • Retention at the inference provider. Anthropic (Claude) models run with Bedrock data-retention mode none (zero retention). For OpenAI (GPT) models, AWS retains classifier-flagged traffic for up to 30 days, inside the AWS boundary, for automated abuse detection. Bedrock model-invocation logging is off. This is disclosed in the sub-processor register and the Trust Center.

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PHI is never persisted in audit logs

Audit rows carry the redacted form plus entity-class metadata only — for example, "SSN redacted at offset 42". Original PHI values never land in audit storage at any tier. A narrow forensic-replay path exists through a crypto-shredded, per-request re-identification map with a short dispute window (24h default), but that map is mathematically destroyed when the window closes.

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Where the substrate sits

The provider chain is replaceable at the driver line, but the HASP-owned components above it — identity, policy, audit, and PHI handling — do not move with a provider swap. See Compliance Posture for how the BAA chain fits the broader framework coverage, and Audit Chain for how PHI events are recorded.