Compliance & HIPAA posture

What we actually do — and won't do.

A working operator's compliance document, not a marketing page. Here's the categories of client we refuse, the BAA stack we run on, and the things our system never does — under any client request, at any price.

Document version
v1.4
Last reviewed
May 2026
Counsel
US healthcare attorney on retainer
Entity
Fill the Lobby, Inc. · US-incorporated
Section 01 · Refused categories

Three verticals we refuse outright.

We're a small firm with concentrated regulatory exposure. These three categories carry federal enforcement risk we're not equipped to underwrite — and so we don't take them, regardless of fee, scope, or relationship.

This list is non-negotiable. Every retainer contract includes it explicitly. If your work touches any of these categories, even adjacent, please don't book the call — we'd have to decline.

×
Addiction-treatment, substance-use disorder, recovery Including SUD treatment centers, methadone clinics, sober homes, and any patient-marketing or referral arrangement involving these services.
EKRA · 42 CFR Part 2 · federal patient-brokering exposure
×
Compounded weight-loss medications Including compounded GLP-1s (semaglutide, tirzepatide), compounded HRT marketing, and any active marketing of compounded medications outside FDA shortage authorization.
FDA enforcement · 503A pharmacy law · evolving regulation
×
Personal-injury law and PI-adjacent practices Including PI law firms, chiropractic practices that primarily bill PI cases, and medical practices whose primary marketing channel is PI law referral.
Different category · different ethics framework · out of scope
Section 02 · HIPAA posture

There is no such thing as "HIPAA certified."

We need to start here because so many vendors lie about it. HHS does not issue HIPAA certifications. No third party has authority to "certify HIPAA compliance." Anyone selling you a HIPAA-certification logo is selling you marketing collateral, not regulatory protection.

What actually exists is a posture: a set of administrative, physical, and technical safeguards a covered entity (your practice) and its business associates (us, our subprocessors) implement and document. The posture either holds up under an OCR audit or it doesn't. The certification logo doesn't help you in either case.

What we operate, by way of posture:

If you're shopping vendors and want to compare postures: ask them to send you their BAA template, their subprocessor list, and the name of their healthcare counsel. Anyone who can't produce all three within 24 hours probably shouldn't have your patient data.

Section 03 · The subprocessor stack

Every vendor that touches patient data, with BAA status.

Reviewed quarterly. We add, remove, and renegotiate based on enforcement signals and posture changes. If you're booked into a retainer or AI receptionist, you receive an updated copy any time this list changes.

Vendor
Role
BAA
Twilio
Telephony, SMS, programmable voice for AI receptionist routing
Signed
ElevenLabs
Voice synthesis (output only) for AI receptionist call audio
Signed (Enterprise)
Azure OpenAI
Reasoning layer for AI receptionist; training opt-out enabled
Signed (Healthcare tier)
Postmark
Transactional email for booking confirmations and reminders
Signed
Calendly / Cal.com
Calendar/booking layer (write-only on our side)
Signed where applicable
Google Workspace (operator inbox only)
Internal operator email; never patient-facing
Signed
GA4 / Google Tag Manager
Marketing analytics; PHI-stripped events only
N/A · No PHI
Meta Conversions API
Server-side ad attribution; PHI-stripped events only
N/A · No PHI
Internal logging (our infra)
Encrypted at rest, 30-day rolling retention, hard-delete on request
First-party
Section 04 · What our system never does

Things our system doesn't do, regardless of client ask.

These aren't things we politely decline when asked — they're things our system structurally won't do. We've designed the architecture so that even if a junior team member tried, the action would fail. Defense-in-depth, not policy-on-paper.

Section 05 · State-by-state escalation

When state law gets weird, who we call.

HIPAA is federal. State law often goes further — especially around telehealth scope, corporate practice of medicine, and consent for marketing communication. The right answer in Texas isn't always the right answer in California or New York.

For state-specific questions, we work with US-licensed healthcare counsel on retainer. The cost of that retainer is built into our fees — clients don't pay separately for legal review of marketing approach in a new state.

Common state-level questions we send to counsel:

Section 06 · Found something that doesn't add up?

If something here looks off, tell us.

We're a working operator. Documents drift. Posture changes. Vendors get acquired and BAAs need renegotiation. If you read this and something looks wrong, missing, or out of date — we'd genuinely like to know about it.

For compliance questions, vendor diligence requests, or counsel-to-counsel inquiries, the fastest path is to book a 15-minute call below — we'll route to the right person internally and respond on the call.

Compliance question

Vendor diligence, BAA review, or just a question.

Fifteen minutes on a call. We'll route the question to the right person internally and respond on the call.

Book a 15-minute call

For counsel-to-counsel review, mention "compliance" in the form.

Book a 15-minute call