HIPAA-Compliant AI Note Takers for Healthcare Meetings: 2026 Buyer's Guide

Which AI note takers sign a BAA, what HIPAA actually requires, and a checklist for vetting a meeting notetaker before PHI comes up in your calls.
On this page
- What makes an AI note taker HIPAA compliant?
- The business associate agreement (BAA)
- Technical safeguards
- What stays your responsibility
- Where AI note takers fit in healthcare (and where they don’t)
- HIPAA checklist: 7 questions to ask any AI note taker vendor
- Which AI note takers support HIPAA?
- How Fireflies supports HIPAA compliance
- How to set up an AI note taker for HIPAA sensitive meetings
- FAQ
- Is AI HIPAA compliant?
- Which AI is HIPAA compliant?
- Is Otter.ai HIPAA compliant?
- Is Fireflies HIPAA compliant?
- Do I need a BAA to use an AI note taker?
- Is there a HIPAA certification for software?
- Conclusion
Healthcare team meetings often carry protected health information (PHI). A care team huddle covers a patient’s diagnosis and discharge plan, and a payer call about a denied claim can bring up treatment history and a member ID. Any AI note taker that records those meetings has to be Health Insurance Portability and Accountability Act (HIPAA) compliant, because its vendor ends up storing the PHI and becomes a business associate with legal duties under HIPAA.
But no certificate proves a vendor fulfills those duties. The Department of Health and Human Services (HHS) says no rule requires an organization to “certify” its HIPAA compliance, and it doesn’t endorse private certifications. An AI note taker becomes HIPAA compliant through a contract and the safeguards behind it, which is why compliance teams ask for a signed business associate agreement (BAA) before approving one.
In this guide, you’ll learn what HIPAA expects from a note taker vendor, which tools sign a BAA and on which plans as of November 2026, and the questions and setup steps that keep HIPAA compliant meeting transcription covered from the first recording.
What makes an AI note taker HIPAA compliant?
An AI note taker is HIPAA compliant for your organization only when its vendor signs a business associate agreement (BAA) with you and runs the safeguards the HIPAA Security Rule requires. The BAA matters because HIPAA lets an organization share PHI with a vendor only after getting written assurance that the vendor will protect it, and the BAA is that assurance. Without one, sharing PHI with the vendor is an impermissible disclosure, even if nothing leaks.
The same goes for meetings outside the BAA’s scope. If the vendor ties its BAA to a specific plan or setting, your workspace has to be on it. The safeguards are a separate obligation, and a vendor that skips them violates both the Security Rule, which applies to business associates directly, and the terms of its BAA.
Each condition has details to check before you sign:
The business associate agreement (BAA)
A BAA is the contract between your organization and a business associate, the HHS term for a vendor that creates, receives, maintains or transmits PHI on your behalf. HHS’s business associate guidance names “the vendor of an app, that provides transcription services to a physician” as one example, and an AI note taker whose vendor stores your meeting transcripts fits the same description.
The contract sets the rules for how that vendor handles your PHI. According to HHS’s sample BAA provisions, it spells out what the vendor may and may not do with the data and requires safeguards that meet the Security Rule. It also obliges the vendor to report breaches to you, and to return or destroy the PHI when the contract ends.
Those obligations follow the data past the vendor. Under 45 CFR 164.502(e), a business associate has to get the same written assurances from any subcontractor that handles PHI, and you don’t have to get them yourself. If a note taker sends audio or transcripts to an outside AI model provider for transcription or summaries, that provider is a subcontractor, and its agreement with the vendor has to carry the same restrictions as your BAA.
Technical safeguards
The BAA commits the vendor to the Security Rule, and the rule’s technical safeguards, at 45 CFR 164.312, are the part you can check in the product itself. They apply to PHI in electronic form (ePHI), which is what meeting recordings and transcripts are, and access control, audit controls and encryption apply to them most directly.
Access control decides who can reach that data. The rule requires systems to “allow access only to those persons or software programs that have been granted access rights,” and it requires a unique name or number for every user. In a note taker, access rights decide who can open a recording or transcript and who receives a shared summary. The unique ID requirement means each person signs in with their own account, so a shared team login fails it. Single sign on (SSO) and role permissions are the settings to look for.
Audit controls are the record of that access. The rule calls for mechanisms that “record and examine activity in information systems” holding ePHI. In practice, that means logs showing who viewed or shared a meeting record, and when. If a recording ends up somewhere it shouldn’t, those logs are how you trace who opened it.
Encryption works differently from those two. The current rule lists encryption of stored ePHI and of ePHI in transit as “addressable,” and addressable still carries an obligation. 45 CFR 164.306(d)(3) says an organization has to implement an addressable safeguard when it’s reasonable and appropriate, or document why not and put an equivalent measure in place. HHS proposed in December 2024 to make encryption at rest and in transit required, with limited exceptions, and says the current rule stays in effect while that rulemaking continues. Either way, ask how a note taker encrypts recordings on its servers and on the way to them.
What stays your responsibility
Your own HIPAA duties stay with you after the vendor signs. The Privacy Rule’s minimum necessary standard requires covered entities to limit PHI use and disclosure to what a task needs, and to identify which workforce members need access to which information. For meeting notes, that means deciding who on your team can open a payer call’s transcript, and whether that recording belongs in a workspace the whole company can search.
You also decide which meetings get recorded in the first place. A weekly operations sync that never touches patient information produces a recording with no PHI in it, which HIPAA doesn’t cover. A case review that names patients needs the HIPAA setup in place before anyone records it, or it shouldn’t be recorded at all.
Where AI note takers fit in healthcare (and where they don’t)
AI note takers fit the meetings healthcare teams hold about patients and the business, where people make decisions and someone needs a record of who agreed to what. Patient visit documentation is the exception.
A HIPAA compliant note taking app earns its place in these meetings, and PHI can come up in any of them.
- Care team huddles, where nurses, case managers and physicians work through shift handoffs and flag patients who need follow up.
- Payer and provider calls about prior authorizations, which often run through a patient’s diagnosis codes and planned procedures.
- Operations and admin meetings on staffing or the revenue cycle. PHI shows up less often here, but one scheduling conflict can still name a patient.
- Telehealth operations reviews on platform problems and visit volume, where troubleshooting a dropped visit can mean pulling up the patient involved.
- Calls between a health tech vendor and its hospital or clinic customers. A support call that turns into a walkthrough of an actual patient’s record puts PHI into the recording, and the note taker’s vendor becomes a subcontractor that needs its own BAA with the health tech company.
- Compliance reviews. An incident investigation may go through exactly whose records were accessed, and by whom.
However, a note taker built for meetings produces a recap of decisions and action items for the people on the call, and a visit note has to be a clinical record the clinician reviews and signs. Visit notes are part of the patient’s medical record, live in the electronic health record (EHR) the practice uses, and usually follow a clinical format such as SOAP (subjective, objective, assessment, plan). A clinical scribe built for that workflow is the better tool for the exam room. Therapists weighing those tools can start with our guide to the AI notetaker for therapists.
HIPAA checklist: 7 questions to ask any AI note taker vendor
Before you trust a vendor with HIPAA compliant transcription, ask it these seven questions and get the answers in writing:
- Will you sign a BAA?
A no ends the evaluation, because without a BAA you can’t share PHI with that vendor at all. - Which plan includes the BAA?
Get the plan named in writing. If the BAA comes with one plan only, a department that signs up on its own for a cheaper plan is recording outside it. - Does the BAA cover the AI features?
Ask which AI features stay on once HIPAA is enabled, and which outside AI providers touch your audio or transcripts. Each of those providers should be bound to your BAA’s restrictions as a subcontractor. - Is customer data used to train AI models?
Training a model on your recordings is a use of PHI, and a business associate may use PHI only in the ways its BAA permits. Ask for the vendor’s training policy in writing, and check that the BAA matches it. - Can we set retention and automatic deletion?
Shorter retention means less PHI sitting on the vendor’s servers. Ask whether admins can set it for the whole workspace, since a workspace rule still applies when someone forgets to delete a recording. - How is data encrypted, and where is it stored?
Ask how recordings are encrypted at rest and in transit, and where the servers are. HHS expects you to understand a cloud vendor’s environment well enough to include it in your own risk analysis. - What admin controls exist?
SSO and role permissions decide who can open a transcript, and audit logs show who did.
A vendor that can’t answer those questions clearly might not be ready for meetings where PHI comes up.
Which AI note takers support HIPAA?
AI note takers that support HIPAA include Fireflies, Otter.ai, Fathom, Zoom, Read AI and Granola, each of which offers a BAA. The differences sit in which plan carries the BAA and what each vendor needs set up first.
| Tool | HIPAA support | BAA available | Plan required | Source |
|---|---|---|---|---|
| Fireflies | Yes | Yes, signed online | Enterprise, with Private Storage enabled | Fireflies BAA, HIPAA setup guide |
| Otter.ai | Yes | Yes, through your account executive | Enterprise, as an add-on | Otter HIPAA help article, Otter pricing |
| Fathom | Yes | Yes, a blanket BAA in its terms or a signed BAA on request | Team plan and above for the standard BAA, custom BAA on Enterprise | Fathom HIPAA help article, Fathom BAA, Fathom pricing |
| Zoom (ZoomMate) | Yes | Yes | Paid plans (Pro at checkout, Business and up through sales) | Zoom BAA support article |
| Read AI | Yes | Yes | Annual Enterprise+, with SAML SSO and domain capture set up | Read AI security overview, Read AI HIPAA article |
| Granola | Yes | Yes, through its sales team | Enterprise only | Granola HIPAA help article |
- Fireflies supports HIPAA compliance on its Enterprise plan with a signed BAA, and the BAA takes effect only once Private Storage is turned on.
- Otter.ai is HIPAA compliant on its Enterprise plan, where HIPAA compliance is an add-on. Its help center says the BAA has to be signed before any PHI is handled. For a fuller side by side, see Fireflies vs Otter.
- Fathom says on its help center that it is HIPAA compliant. It points to a blanket BAA in its terms and will sign a BAA directly on request, and its pricing page lists a standard BAA on the Team plan and a custom BAA on Enterprise.
- Zoom signs BAAs on its paid plans. Its BAA article says AI features, including ZoomMate, are available to customers with a BAA, with the caveat that certain AI features may not be available yet for healthcare customers. Ask Zoom which ones.
- Read AI signs a BAA only on an annual Enterprise+ plan, after SAML SSO and domain capture are in place. In a HIPAA workspace, its Ada executive assistant is unavailable and push integrations to tools such as Salesforce stay off until an admin turns them back on.
- Granola offers HIPAA support and a BAA on its Enterprise plan only, and its sales team handles the setup.
How Fireflies supports HIPAA compliance
Fireflies is HIPAA compliant on its Enterprise plan once the workspace has a signed BAA and Private Storage turned on. Fireflies is SOC 2 Type II, GDPR, and HIPAA compliant, and ISO/IEC 42001 certified. SOC 2 Type II and GDPR cover every plan, including Free.
Private Storage keeps your organization’s meeting data in its own storage bucket, separate from other customers, in a region you pick during setup. Private Storage is enabled from Settings, the BAA is signed separately, and the Security Checklist in Team Settings shows when both are complete. Fireflies’ HIPAA setup guide warns that “plan downgrades or storage changes will immediately disable HIPAA compliance,” which makes it worth naming an owner for those settings on your side. Fireflies’ Private Storage guide walks through setup and how storage locations work.
The BAA limits how Fireflies can use that meeting data, and training AI models on it would be a use of PHI. Fireflies doesn’t train on customer data, on any plan including Free, and it sets terms for the outside AI vendors that process meeting content too.
Retention inside your own workspace is set by your admins. On Enterprise, an admin can turn on automatic deletion for the whole workspace, with a window anywhere from one week to two years, and lock the setting so teammates can’t change it.
Admins also control who can reach that data. Enterprise adds SSO with SCIM provisioning and audit logs, the controls the Security Rule’s access and audit safeguards call for. Behind those controls, meeting notes and transcripts are encrypted with AES 256 at rest and with TLS in transit.
How to set up an AI note taker for HIPAA sensitive meetings
An AI note taker is ready for HIPAA sensitive meetings once the vendor’s BAA and the settings it depends on are in place, and that has to happen before anyone records a meeting with PHI. Retention, access and consent controls then cover every meeting after that.
Here are the five steps to set up an AI note taker for meetings that involve PHI:
- Sign the BAA before the first recording
Get it signed on the plan you’re buying. A meeting recorded the day before the signature has no BAA behind it. - Turn on the settings the BAA depends on
Some vendors tie the BAA to a configuration, such as a dedicated storage setting that has to be on for the BAA to take effect, or single sign on that has to be set up before they’ll sign. Check that the vendor’s admin console shows HIPAA as active. - Set retention
Pick the shortest window that still covers how long your team needs meeting records, and set it for the whole workspace. - Restrict access and sharing
Start with which meetings the note taker joins on its own, and limit automatic joining to the ones you mean to record. Then limit who receives transcripts by default, require SSO and turn off public and link based sharing. Some vendors leave that last step to you. - Tell participants they’re being recorded
Say it at the start of every recorded meeting, and check the consent rules where each participant is. Our guide to recording laws by state covers which states require every party’s consent.
FAQ
Is AI HIPAA compliant?
An AI tool is HIPAA compliant only when its vendor signs a business associate agreement (BAA) with your organization and protects the data with the safeguards the HIPAA Security Rule requires. HIPAA doesn’t approve or certify AI tools. Under HHS rules, any AI vendor that creates, receives, maintains or transmits PHI for you is a business associate.
Which AI is HIPAA compliant?
AI note takers that support HIPAA include Fireflies, Otter.ai, Fathom, Zoom, Read AI and Granola, according to each vendor’s own pages as of November 2026. Each offers a BAA, but on different plans. Fireflies, Otter.ai and Granola offer it on Enterprise, Read AI on annual Enterprise+, Zoom on paid plans and Fathom on its Team plan and above.
Is Otter.ai HIPAA compliant?
Yes, Otter.ai is HIPAA compliant on its Enterprise plan. HIPAA compliance is an add-on there, and the BAA is signed through your account executive. Its help center says Otter.ai becomes a business associate only once that BAA is in place, and that customers must turn off public and link based transcript sharing when PHI is involved.
Is Fireflies HIPAA compliant?
Yes, Fireflies is HIPAA compliant on its Enterprise plan once the workspace has a signed BAA and Private Storage turned on. However, a plan downgrade or storage change turns HIPAA off right away. Fireflies’ Free, Pro and Business plans don’t include HIPAA.
Do I need a BAA to use an AI note taker?
Yes, you need a business associate agreement (BAA) to use an AI note taker in meetings where PHI comes up. HHS treats any vendor that handles PHI on your behalf as a business associate, and HIPAA lets you share PHI with that vendor only after it gives written assurance in a BAA. Meetings that never involve PHI don’t need one.
Is there a HIPAA certification for software?
No, there is no HIPAA certification for software. HHS says no rule requires an organization to “certify” its HIPAA compliance, and it doesn’t endorse private certifications. A “HIPAA certified” badge on a vendor’s site is the vendor’s own claim. To check a vendor, ask for a signed BAA and independent audit reports such as SOC 2 Type II.
Conclusion
Choosing a HIPAA compliant AI note taker comes down to whether the vendor signs a BAA on the plan your team will use and keeps its AI features available under that BAA. After signing, compliance depends on the settings your admins choose and on telling participants they’re being recorded. But vendors can revise those terms after you sign. Check each vendor’s current BAA and plan page before signing, and again at renewal.
Fireflies is an AI Teammate that’s HIPAA compliant on its Enterprise plan once the workspace has a signed BAA and Private Storage turned on. Its HIPAA setup guide walks through both in order. Start with a free account to see how Fireflies works while your compliance team reviews the BAA, and bring in meetings with PHI once HIPAA is on with Enterprise.

Lynn Wang is a content strategist and editor with 8+ years covering technology, AI, and fintech. She has run newsroom operations and published 500+ articles, turning complex, technical topics into clear, accurate writing for mainstream readers.

