Will you negotiate the BAA terms with providers for us?

We provide engineering input your legal counsel needs to negotiate accurately. Your legal counsel does the legal negotiation. Roles are deliberately separated. We have working relationships with most major providers' enterprise teams and can introduce your team where helpful.

Can this run before Discovery Sprint, or only after?

Either. Before: builds compliance foundation Discovery leverages. In parallel: engagements complete together at 4 weeks. After: implements Discovery's architecture. Most common: parallel with Discovery or MVP Sprint.

What is not included in this $80K?

Buyer legal counsel fees for BAA review. Custom subprocessor engineering work beyond standard provider integrations. Ongoing compliance monitoring (use Care Packages). FDA SaMD work if applicable (separate add-on).

Do you re-execute existing BAAs or just review them?

We audit existing BAAs for scope, coverage, and configuration alignment. If adequate, we document and move on. If material gaps exist, we work with your legal counsel on amendments or replacement BAAs. Decision happens in Phase 1.

How do you handle multi-tenant BAA structure?

Each downstream covered entity needs its own BAA with you, and upstream provider BAAs need to cover multi-tenant configuration. Tenant isolation at inference, audit log, and embedding store layers is architectural work in the engagement scope.

Custom Software

BAA Network Setup Add-On — 6 Weeks, $80K, BAA-Eligible AI Infrastructure From Standing Start

A healthcare AI team that wants to ship a feature in 60 days does not have 60 days to figure out BAA infrastructure from scratch. The Business Associate Agreements with model providers take 2–8 weeks to execute. The PHI redaction layer needs engineering. The audit logging needs to be tamper-evident. Configuration verification needs documentation. The subprocessor chain needs mapping. Each piece can be built in parallel, but none can be skipped — and a hospital security review will spot a missing piece in fifteen minutes.

The BAA Network Setup Add-On is the productized 6-week engagement that delivers all of it together. $80,000 fixed. End-to-end BAA-eligible AI infrastructure ready for hospital security review and production deployment. Runs in parallel with the Discovery Sprint or MVP Sprint, or as a standalone engagement for teams that already have an AI feature but need the compliance foundation under it.

For the architectural overview of BAA coverage across AI providers, see the BAA with AI providers page. For the underlying technical depth, our BAAs with OpenAI, Anthropic, and AWS Bedrock guide covers the field-tested mapping we use. This page is the productized service-delivery side.

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What “BAA Network” Actually Means

The phrase “BAA Network” describes the full subprocessor chain that touches Protected Health Information in a healthcare AI deployment. Not one BAA. The whole network of BAAs.

For a typical production AI feature, the network includes:

The inference model provider (Azure OpenAI, AWS Bedrock for Anthropic, Google Vertex AI, OpenAI direct, or on-prem)

The embedding model provider (often the same as inference, sometimes different)

The vector database provider if PHI-bearing embeddings are stored

The audit logging vendor (cloud-native logging services, third-party SIEM, or self-hosted)

The PHI redaction service if cloud-based (Comprehend Medical, Azure Health Data Services, custom service)

The application hosting infrastructure (AWS, Azure, GCP)

Any downstream observability tooling that may see PHI in metadata

The 6-Week Schedule

Three two-week phases. Each phase produces concrete artifacts that move the buyer closer to a hospital-deployable AI stack.

Phase 1 (Weeks 1–2) — Architecture Mapping and Provider Selection

We map the existing or proposed AI stack to identify every PHI processing event in the chain. Document the current state. Identify gaps in BAA coverage, configuration, and subprocessor visibility. Recommend provider selection if not yet chosen — Azure OpenAI versus AWS Bedrock versus Vertex versus on-prem decision based on the specific use case, latency requirements, on-prem constraints, and cost profile.

End of Phase 1: a written architecture document showing the BAA network with gaps explicitly marked, plus provider recommendations.

Phase 2 (Weeks 3–4) — BAA Execution and Configuration

We coordinate with the buyer’s legal counsel on BAA execution with each provider in the network. Most major providers have standard BAA templates — Microsoft for Azure OpenAI, AWS for Bedrock, Google for Vertex — but the templates often need amendments for AI-specific scope clarifications (which endpoints are covered, which beta features are excluded, which configurations qualify for coverage). We provide the engineering input the legal team needs to negotiate accurately.

Configuration verification runs in parallel: zero-data-retention turned on, customer-managed keys configured where supported, BAA-eligible regions selected, opt-out of training data use confirmed.

End of Phase 2: BAAs executed (or in legal review) with every provider in the network. Configuration verified and documented.

Phase 3 (Weeks 5–6) — Engineering Implementation and Documentation

PHI redaction layer deployed at the inference boundary if not already in place — see PHI redaction services for what that layer looks like in engineering detail. Audit logging deployed at HIPAA §164.312(b) granularity — see healthcare AI audit logging service for the underlying engineering. Documentation package assembled for hospital security committee submission.

End of Phase 3: production-ready BAA network in place, with documentation package complete and security-review-ready.

Six Outputs the Add-On Produces

1. BAA network architecture document. Subprocessor chain mapped end to end, each entity identified with its BAA scope and configuration. The diagram hospital security review will ask to see.

2. BAA execution status. Every provider in the network has either an executed BAA or a documented in-legal-review status with expected close date. No silent gaps.

3. Configuration verification report. Zero-data-retention status per provider, customer-managed key configuration, BAA-eligible region selection, opt-out of training data use confirmed in writing. Cross-checked against the actual deployed configuration, not just the documented intent.

4. PHI redaction layer. Operational redaction at the inference boundary with audit logging of redaction actions. If a layer already exists, we audit it; if not, we deploy. See PHI redaction services.

5. Audit logging infrastructure. Inference-level audit logging running, append-only with cryptographic tamper-evidence. See healthcare AI audit logging service.

6. Hospital security committee documentation package. PHI flow diagram, BAA chain document, configuration evidence, audit log retention policy, model cards for inference providers, subprocessor BAA references. The single packaged deliverable that hospital security committees review.

How This Differs From the BAA Architecture Overview Page

The BAA with AI providers page is the architectural and educational layer — what BAAs cover, how providers differ, what configuration matters. It is the conceptual frame.

This add-on is the productized service that executes the architecture. We do the work: BAA execution coordination with legal, configuration verification, engineering deployment of redaction and audit logging, documentation package assembly. The architectural page tells you what needs to happen; this add-on makes it happen in 6 weeks for $80K.

The two pages reference each other but serve different intents: architectural overview versus productized service engagement.

When This Is the Right Engagement

This add-on fits when:

The team is starting from zero on BAA infrastructure with major AI providers

The team has BAAs in place but with significant gaps in scope, configuration, or documentation

The team is preparing for hospital security committee review of an AI feature

The team needs SOC 2 Type II or HITRUST evidence that BAA infrastructure is operating correctly

The team is migrating between providers and needs the new BAA network set up cleanly

Production reality

How It Pairs With Other Engagements

The most common pairing combinations:

With Discovery Sprint. Runs in parallel during the 4-week Discovery. By Discovery end, the buyer has both the architectural plan (Discovery output) and the BAA infrastructure foundation underway (this add-on). Combined: $125K over 4 weeks.

With MVP Sprint. Runs in parallel during the first 6 weeks of the 8-week MVP. The BAA network completes around Sprint 2 of MVP, in time for real PHI to flow through the stack. Combined: $175K over 8 weeks.

Standalone for existing AI deployments. When the buyer has shipped an AI feature and discovered compliance gaps under audit pressure, the add-on retrofits the BAA network without rebuilding the feature. Standalone: $80K, 6 weeks.

Combined with PHI redaction and audit logging Sprints. When the existing application needs both BAA infrastructure and significant engineering work on redaction and audit logging, the add-on is paired with the PHI redaction services and healthcare AI audit logging service pages — same team, coordinated delivery.

Engagement Logistics

Pricing. $80,000 fixed. Two payment milestones: 50% on contract signature, 50% at end of Phase 2 (BAAs executed or in legal review with documented status).

Timeline. 6 weeks calendar from kick-off. Most engagements kick off 1–3 weeks after contract signature.

Contracting. MSA plus SOW. References parallel Sprint engagement when applicable.

Team. A senior HIPAA compliance engineer leads the engagement, paired with a healthcare AI engineer for the technical implementation and a compliance advisor for the BAA execution coordination with the buyer’s legal counsel.

What we do not do. We do not act as the buyer’s legal counsel on BAA terms. The buyer’s legal counsel reviews and signs the BAAs; we provide the engineering input on AI-specific scope clarifications. We also do not act as the cloud-provider account owner; the buyer’s organization owns its provider accounts and the BAA contracts.

FAQs

Frequently Asked Questions About the BAA Network Setup Add-On

We provide the engineering input your legal counsel needs to negotiate accurately — which endpoints are in use, which configurations are deployed, which beta features matter, what your subprocessor chain looks like. Your legal counsel does the legal negotiation. The two roles are deliberately separated. We have working relationships with most major providers’ enterprise teams and can introduce your team where helpful.

Some providers do not sign BAAs at any tier (OpenAI direct used to be one; that has shifted). When a provider in your architecture is BAA-unwilling, the recommendation in Phase 1 is either to migrate to a BAA-eligible alternative (Azure OpenAI, AWS Bedrock, Vertex AI, on-prem) or to architect around the provider by keeping PHI out of its path. Phase 1’s architecture document calls this out explicitly.

Either. When run before, the add-on builds the compliance foundation that Discovery’s architecture work then leverages. When run in parallel with Discovery, the two engagements complete together at 4 weeks (add-on continues 2 more weeks). When run after Discovery, the add-on implements the architecture Discovery designed. Most common pattern: parallel with Discovery or with MVP Sprint.

Yes. Phase 1 maps the existing subprocessor chain and identifies which existing BAAs are in force, which need scope expansion, and which are missing. We coordinate with your legal counsel on remediation across the existing chain.

The buyer’s legal counsel fees for BAA review and execution (typically $5K–$25K depending on legal firm and complexity). Custom subprocessor engineering work beyond standard provider integrations (e.g., custom clinical NER training — see PHI redaction services). Ongoing compliance monitoring after the add-on completes (use Care Packages for that). FDA SaMD work if applicable (use the FDA SaMD pathway add-on).

We audit existing BAAs for scope, coverage, and configuration alignment. If existing BAAs cover the current use case adequately, we document that and move on. If existing BAAs have material gaps, we work with your legal counsel on amendments or replacement BAAs as needed. The decision happens in Phase 1.

Each downstream covered entity (your customer) needs its own BAA with you, and the upstream provider BAAs need to cover the multi-tenant configuration. Tenant isolation at the inference layer, audit log layer, and embedding store layer is architectural work that fits inside the engagement scope. Multi-tenant BAA structure is common for digital health AI vendors and we handle it routinely.