"OCR's Health App Guidance details six scenarios in which Health Apps collect, store and/or transmit health information directly from consumers ... The Health App Guidance also clarifies that a health app that is downloaded and used solely by individual consumers does not result in the app developer's becoming subject to HIPAA ... However, a developer who contracts directly with a CE to collect, maintain or transmit PHI through a particular health app is deemed to be a BA under HIPAA, and accordingly will be subject to HIPAA requirements ... A developer who contracts with a BA on behalf of a CE to do the same thing likewise will be subject to HIPAA."  MORE >>