Email aliases can be HIPAA compliant with proper security measures, like encryption, having a business associate agreement (BAA) with the email service provider, implementing strong access controls, and maintaining audit logs. Using an alias doesn't introduce compliance risks. However, how PHI is handled through that alias must adhere to HIPAA's privacy and security standards.
What are email aliases?
An email alias is a “shortcut” email address that routes messages to a designated inbox. Instead of creating multiple accounts, organizations can use aliases to manage communications for different departments or services without needing separate mailboxes. In healthcare, aliases might be used to manage emails for specific purposes, such as scheduling (appointments@clinic.com) or billing (billing@clinic.com), while all correspondence is stored in one central inbox. Based on a study on email alias detection, “Aliases can be tailored to specific scenarios, which allows individuals to assume different aliases depending on the context of interaction.”
HIPAA’s requirements for email communication
The HHS clarifies that "the Privacy Rule allows covered health care providers to communicate electronically, such as through e-mail, with their patients, provided they apply reasonable safeguards when doing so." The Security Rule requires safeguards to ensure the confidentiality and integrity of electronic PHI. When it comes to email, HIPAA requires:
- Encryption of PHI to protect it in transit and at rest.
- Access controls to limit who can access PHI.
- Audit trails to monitor email access and activity.
- Business associate agreements (BAAs) with third-party providers handling PHI, including email services.
These requirements apply regardless of whether the communication involves a primary email address or an alias.
Can email aliases be HIPAA compliant?
Email aliases can be HIPAA compliant, but compliance depends entirely on how they are used and secured. Aliases themselves do not present any additional compliance risks, rather, it’s how PHI is handled in those emails that matters.
If PHI is transmitted or stored in emails sent to or from an alias, the healthcare provider must follow HIPAA’s rules for securing that information. The same encryption, access control, and audit requirements that apply to primary email addresses also apply to email aliases.
Requirements for making email aliases HIPAA compliant
- Encryption: Any email containing PHI, whether sent via an alias or a primary email, must be encrypted to protect it from unauthorized access.
- Business associate agreement (BAA): Healthcare providers must have a BAA with their email service provider. The BAA ensures that the provider adheres to HIPAA’s rules when handling PHI, including email communication through aliases.
- Access controls: Access to the inbox associated with email aliases must be restricted to authorized personnel. Use strong passwords, multi-factor authentication (MFA), and limit account access to ensure only the right individuals can view or send PHI.
- Audit logs and monitoring: HIPAA requires tracking who accesses and sends emails, including those through aliases. Maintaining audit logs helps monitor email activity and ensure compliance with security protocols.
- Minimum necessary rule: When sending PHI through an email alias, only include the minimum necessary information to reduce the risk of oversharing sensitive data and violating HIPAA’s privacy standards.
Mistakes that could make email aliases non-compliant
- Using non-secure email providers that don’t offer encryption. Healthcare organizations should rather opt for HIPAA compliant email providers like Paubox to avoid violating HIPAA.
- Failing to sign a BAA with the email service provider.
- Not restricting access to inboxes can lead to unauthorized viewing of PHI.
- Sending unnecessary PHI in email aliases violates the Minimum Necessary Rule.
Related: The consequences of not having a BAA with an email service provider
FAQs
Do I need to inform patients if I use email aliases for communication?
It’s a best practice to inform patients about how their communications are handled, including email aliases, especially when sensitive information is involved, to maintain transparency and trust.
Is it a HIPAA violation to forward emails from an alias to a noncompliant email account?
Forwarding emails containing PHI to a non-compliant or unsecured email account can be a violation of HIPAA, as it may expose sensitive patient information to unauthorized access.
Read more: Is it a HIPAA violation to forward an email?
Can email aliases be used with automated systems like appointment reminders?
Yes, but any automated system sending emails containing PHI must comply with HIPAA requirements, including encryption and ensuring that the service provider has signed a BAA.
Liyanda Tembani
