What HIPAA actually requires of a voice agent
HIPAA does not certify software; it obligates covered entities and their business associates. For a voice agent that means three things in practice: a signed Business Associate Agreement (BAA) with every vendor that can see protected health information (PHI), technical safeguards (encryption in transit and at rest, access control, audit logging), and a documented retention and breach-notification process. A voice call is unusually leaky because PHI exists in four forms at once — raw audio, interim transcripts, LLM prompts and completions, and synthesized speech — and each of those can be logged by a different vendor.
Vapi's BAA and enterprise posture
Vapi offers a BAA on its enterprise/HIPAA plans rather than on self-serve accounts. Before you handle real patient data, confirm three things in writing: that the BAA is executed, which Vapi subprocessors are covered, and whether your account has HIPAA mode enabled (this is what disables long-term call recording and transcript retention on Vapi's side). Do not assume a self-serve account inherits the enterprise terms — the defaults keep recordings and transcripts for dashboard debugging, which is exactly what you must turn off.
Zero data retention configuration
- Disable call recording at the assistant level, not just in the dashboard UI.
- Disable transcript persistence, or route transcripts to your own HIPAA-eligible store via webhook and keep nothing on the vendor side.
- Set the shortest available log retention on every provider that supports it, and request zero-retention endpoints where offered.
- Strip PHI from tool-call payloads and webhook bodies — those often land in third-party logging tools nobody audited.
- Turn off vendor model-training opt-ins; most providers train on API data unless explicitly disabled or covered by a BAA.
HIPAA-eligible upstream providers
Vapi is an orchestrator, so your compliance boundary is only as strong as the providers you plug in. For speech-to-text, Deepgram will sign a BAA and offers zero-retention processing. For language models, Azure OpenAI is the common choice because Microsoft's BAA covers it and it supports no-retention abuse monitoring; AWS Bedrock is an equivalent path. For text-to-speech, both Cartesia and ElevenLabs have enterprise agreements that can include a BAA — the self-serve tiers generally do not. Any provider without an executed BAA must never receive PHI, no matter how good the latency numbers look.
PHI redaction techniques
Redaction is your defense in depth for the hops you cannot fully control. Practical techniques: run entity detection over the final transcript and mask names, dates of birth, MRNs, and addresses before persisting anything; keep identifiers out of the system prompt and pass an opaque patient token to your tools instead; use DTMF collection rather than spoken digits for card numbers and member IDs so the audio never contains them; and mask before you log, not after. Assume every log line you write will be read by someone without treatment-relationship authorization.
Secure telephony setup
The carrier leg matters as much as the AI leg. Twilio will sign a BAA and supports SIP over TLS with SRTP media encryption; enable both, and disable Twilio-side call recording. If you bring your own carrier (BYOC) through Vapi's SIP support, confirm that the carrier encrypts media, will sign a BAA, and does not retain recordings for quality monitoring by default. Voicemail, fax bridges, and call-center transfer targets are frequently the weakest link — audit where a transferred call actually lands.
Access control, audit logging, and incident readiness
- Enforce SSO and least-privilege roles on the Vapi dashboard; production assistants should not be editable by everyone.
- Keep an immutable audit trail of who accessed transcripts, in your own system rather than the vendor's.
- Store transcripts encrypted at rest with row-level access scoped to the treating team.
- Write and rehearse a breach-notification runbook covering vendor-side incidents, not just your own.
- Re-review subprocessor lists quarterly; providers add and swap infrastructure vendors often.
A realistic compliant reference stack
A configuration teams actually ship in 2026: Vapi on an enterprise plan with an executed BAA and HIPAA mode enabled, Deepgram Nova streaming STT under a BAA with zero retention, Azure OpenAI GPT-4o-mini for the hot path with abuse-monitoring retention disabled, Cartesia or ElevenLabs enterprise TTS under a BAA, Twilio telephony over TLS/SRTP with recordings disabled, and all transcripts written to your own encrypted database via webhook with PHI masked at write time. Latency is typically 100–200ms worse than an unconstrained stack, which is the fair price of a defensible compliance boundary.