We are ready to sign a Business Associate Agreement
EchoReview AI will execute a HIPAA BAA with any qualified hospital or research institution before handling Protected Health Information. A draft template is available for review by hospital counsel.
HIPAA & compliance readiness
What we have built for safe research use today, and the remaining checklist before a rural-hospital pilot.
Implemented controls
Live in production today
- Audit logsDone
Every view, upload, sign-off, and addendum is timestamped with user ID, IP address, and user agent. Immutable append-only table with study-scoped and org-scoped queries.
- Role-based access control (RBAC)Done
Three clinical roles: technician (upload / view), cardiologist (sign / addendum), and admin (member management). Enforced in both UI and database RLS policies.
- Organization isolationDone
Multi-tenant architecture. Each hospital or research group is a separate organization. Data is fully walled off by org_id in every table with Row-Level Security.
- Two-factor authentication (TOTP)Done
Users can enroll Google Authenticator, 1Password, Authy, or any RFC-6238 TOTP app. 2FA is strongly recommended for all clinical accounts.
- Idle session timeoutDone
Automatic sign-out after 15 minutes of inactivity. Resets on mouse, keyboard, touch, or scroll events.
- Failed-login lockoutDone
5 failed password attempts trigger a 15-minute account lockout per email address, reducing brute-force risk.
- Password re-authentication for sign-offDone
Before a cardiologist finalizes a diagnosis, the platform requires the user's password again — a 21 CFR Part 11–style electronic signature checkpoint.
- Signed-study immutability + addendumsDone
Once a study is signed, core fields are locked. Corrections are made via addendums that create a new audit row, preserving the original interpretation trail.
- Database RLS & encrypted storageDone
Supabase Row-Level Security policies enforce org-scoped access at the database layer. Storage buckets use TLS in transit and AES-256 at rest.
- Invitation-only membershipDone
New org members join via time-limited, tokenized email invitations. No open enrollment. Owners and admins control roster and role assignment.
Remaining for pilot
Needed before a rural-hospital clinical pilot
- Business Associate Agreement (BAA)External
A signed BAA between EchoReview AI and each hospital is required under HIPAA when handling PHI. This is a legal/contractual step, not a technical one.
- Formal HIPAA Security Rule gap analysisIn progress
A documented risk assessment covering administrative, physical, and technical safeguards — including unique-user IDs, emergency access, and automatic logoff.
- FDA 510(k) clearance or CDS exemptionExternal
To market as a diagnostic support tool, the AI module likely needs FDA 510(k) clearance or validation as a Clinical Decision Support (CDS) feature under the 21st Century Cures Act.
- SOC 2 Type II auditIn progress
Independent attestation of security, availability, and confidentiality controls over a 6–12 month observation period. Expected timeline: 3–6 months to achieve.
- Third-party penetration testIn progress
Hire a qualified firm to perform annual network, application, and social-engineering penetration testing with a remediation report.
- Staff training & competency recordsIn progress
Documented training for all users on PHI handling, password hygiene, incident reporting, and the difference between AI output and a final cardiologist interpretation.
- Data retention & deletion policyIn progress
Formal policy defining how long echo images and audit logs are kept, how de-identified research datasets are handled, and the secure-deletion procedure upon patient or hospital request.
- Backup & disaster recovery testingIn progress
Documented Recovery Point Objective (RPO) and Recovery Time Objective (RTO), with quarterly restoration drills.
- Incident response & breach notification planIn progress
Written runbook for detecting, containing, and reporting breaches to affected hospitals and HHS within the required 60-day HIPAA window.
- Physical safeguards (if on-premise)In progress
If any component runs inside the hospital (e.g. a local DICOM bridge), document workstation security, access badges, and video surveillance.
Encryption & access controls
How we protect echo images and patient data from the moment they arrive to long-term storage.
Data-at-rest
Echo images, audit logs, and database backups are encrypted at rest using AES-256. Encryption keys are managed by the cloud infrastructure provider, rotated automatically, and never exposed to application code.
Data-in-transit
Every browser connection, API request, and storage transfer is protected by TLS 1.3. Weak cipher suites and deprecated protocols (SSLv3, TLS 1.0/1.1) are disabled at the edge. Certificate pinning is handled by the platform.
Access control & audit
Row-Level Security policies enforce organization-scoped access at the database layer. Every view, upload, and sign-off is logged with user ID, timestamp, IP address, and user agent in an immutable audit trail.
Interested in a pilot?
We are looking for 2–3 rural or Critical Access Hospitals to run a 90-day quality-improvement pilot. All data stays in your isolated organization workspace. A BAA and IRB approval are prerequisites.