Question 1

How is it legal for Credo Health to access a patient’s medical record?

Accepted Answer

Credo Health doesn’t access patient data on its own. We act as a secure data pipeline, pulling records at the direction of the treating provider—just like traditional chart chasing.
If a doctor is actively treating a patient, they have a legal right under HIPAA to access that patient’s records for care purposes, whether that’s through a faxed chart request or a digital network like Credo Health.
When a provider signs a BAA with Credo Health, we are authorized to streamline the process by connecting to national data exchanges, retrieving the same records a provider would request manually, and making them usable through structured formats and clinical insights.
Everything Credo Health does to retrieve clinical data is HIPAA-compliant, and no data is accessed unless it’s tied to a legitimate treatment relationship.

Question 2

What is the treatment use case for Credo Health’s data acquisition services and why is it HIPAA Compliant? (“Treatment” Use Case)

Accepted Answer

When Credo Health accesses national networks to retrieve patient health records, we do so under the HIPAA-defined treatment use case, with authorization from the covered entity. That means the requesting provider is actively involved in the patient’s care and has a legal right to access relevant medical records from other facilities.
HIPAA permits this type of data sharing when it supports informed, coordinated treatment. Providers can access records by fax, phone call, or a digital tool like Credo Health.
Credo Health streamlines the process. We securely retrieve, aggregate, and organize clinical data, making it faster, easier, and more accurate for providers to get the information they need at the point of care.

Question 3

Why does Credo Health require a partner to sign a Business Associate Agreement?

Accepted Answer

Under the Health Insurance Portability and Accountability Act (HIPAA), covered entities (like health plans and providers) and their business associates are permitted to access and share protected health information (PHI) for purposes of treatment, payment, or healthcare operations.
Credo Health operates as a business associate under HIPAA, which means:

Credo Health has Business Associate Agreements (BAAs) in place with its health plan or provider customers.
These agreements legally authorize Credo Health to access and process PHI on behalf of the covered entity for treatment and risk adjustment-related purposes.

Question 4

How does Credo Health Access National Health Information Networks (HINs)?

Accepted Answer

Credo Health (via Acquire) connects to national health information networks like Carequality, CommonWell, eHealth Exchange, and Healthix. These networks:

Operate under a legal framework that allows real-time, point-to-point data exchange for treatment.
Require participants to comply with data use agreements, certification, and security protocols.
Allow business associates acting under treatment authority (and documented BAAs) to access records for purposes like risk adjustment, suspecting, and care planning.

Question 5

Is Credo Health’s access to these systems legal?

Accepted Answer

Yes, Credo Health’s access is legal because it:

Uses a documented treatment use case
Has valid user authentication and authorization processes
Retrieves data on behalf of a treating entity or plan with appropriate permissions

Question 6

How does Credo Health generate a full appointment history (AI + Datasets)

Accepted Answer

This component of our technology, which we call Acquire (our data acquisition agent), uses proprietary partnerships and non-PHI datasets (such as provider directories, claims-derived metadata, and statistical models) to infer where a patient likely received care. It doesn’t directly expose PHI unless and until those locations are used to retrieve records via legal methods (e.g., manual chases or HIN queries).

The AI pipeline flags potential gaps in care.
Credo Health then fills those gaps using permissible retrieval methods under the treatment use case.

Question 7

How does Credo Health’s manual retrieval process work in a compliant fashion?

Accepted Answer

Manual record retrieval is a long-standing, HIPAA-compliant process where:

Credo Health, acting on behalf of a plan or provider, sends record requests to outside provider offices
These are standard release-of-information (ROI) workflows
Records are returned and ingested into Acquire for suspecting and data reconciliation

Because these chases are initiated under an active BAA for treatment purposes, and proper safeguards are in place, they’re fully legal.

Question 8

Can you summarize what makes Credo Health HIPAA compliant?

Accepted Answer

Credo Health can legally retrieve and process clinical data because it:

Operates as a business associate under HIPAA
Has BAAs with covered entities (health plans or providers)
Uses the treatment use case for real-time and manual data access
Complies with the rules and frameworks governing national health information exchanges

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