HIPAA GUIDES
Do Health Coaches Need to Be HIPAA Compliant?
Short Answer
Often no, but it depends on how you work. HIPAA applies to covered entities and their business associates. An independent coach who is paid directly by clients and does not bill insurance is usually not a covered entity. A coach who works for a medical practice, or handles patient information on its behalf, may fall under that practice's HIPAA obligations.
Who HIPAA Applies To
HHS describes three kinds of covered entities: health plans, health care clearinghouses and health care providers. Providers are covered only if they transmit information electronically in connection with a transaction for which HHS has adopted a standard, such as billing a health plan.
HIPAA also reaches business associates, meaning people or companies that handle protected health information on behalf of a covered entity.
When a Coach Is Usually Not Covered
In that situation HIPAA usually does not apply to your business. This is general information, so check with an attorney if you are unsure.
- You work independently and clients pay you directly
- You do not bill insurance or send claims electronically
- You do not receive patient records from a medical practice as part of your service
When a Coach May Be Covered
If you work on behalf of a practice, that practice will usually ask you to sign a Business Associate Agreement or will treat you as part of its workforce.
- You are employed by a clinic, hospital or other covered practice
- You contract with a practice and receive information about its patients to do your work
- You are also a licensed provider who bills insurance for some services
Not Covered Does Not Mean No Rules
Clients share personal health details with coaches and expect them to stay private. State privacy laws and consumer protection rules can still apply to the information you collect, even when HIPAA does not. Clear consent, limited access and secure tools are good practice either way.
Which Plan Fits a Health Coach
Most independent coaches use the Aspire Builder Pro Standard plan at $97 per month. If you work with medical practices, take referrals that include patient records, or plan to add clinical services, the HIPAA plan at $297 per month includes a signed BAA. See the CRM for health coaches and pricing.
Frequently Asked Questions
This article is general information, not legal advice. Vendor plans and policies change, so confirm details with each vendor before you rely on them. Last reviewed October 10, 2026.
