Read Me — Transmitting PHI Through This Portal
Why this upload channel satisfies your obligations under the HIPAA Security Rule, and what evidence we will put in your hands to prove it.
HIPAA Security Rule — Control Mapping
The Security Rule does not certify vendors; it requires safeguards. Below is each transmission-relevant standard, the control that satisfies it here, and who owns it.
| Standard | 45 CFR | How this portal satisfies it | Owner |
|---|---|---|---|
| Transmission Security Encryption & integrity controls |
§164.312(e) | All traffic to this form is forced over HTTPS/TLS 1.2 or higher with modern cipher suites; HSTS is enabled and plaintext HTTP is refused, not redirected silently. File payloads are encrypted in transit and re-encrypted at rest on arrival — there is no unencrypted intermediate hop and no SMTP leg. | medTRANS |
| Encryption at Rest | §164.312(a)(2)(iv) | Uploaded files and the case database are stored on encrypted volumes (AES-256) inside the Atlantic.Net HIPAA environment. Backups — both onsite and offsite — are encrypted with the same standard. | medTRANS |
| Access Control Unique ID, role-based, minimum necessary |
§164.312(a)(1) | Submissions are received by our automated intake process and deposited directly into a permissioned SharePoint case-file folder to which only the Underwriting team and the Executive team hold access. Every user holds a unique named account with multi-factor authentication — no shared logins, no shared inbox, no general-staff access. Developers, infrastructure personnel, and IT vendors are excluded from PHI access by design, not by promise. | medTRANS |
| Audit Controls | §164.312(b) | Upload, access, download, and deletion events are written to an immutable audit log with user, timestamp, and IP. Logs are retained and reviewable, and we will produce the access history for your client's submission on request. | medTRANS |
| Integrity | §164.312(c)(1) | Each file is checksummed on receipt; the stored copy is verified against the hash you uploaded. File-integrity monitoring runs continuously on the host, so silent alteration is detectable rather than assumed away. | medTRANS |
| Person / Entity Authentication | §164.312(d) | The certification block on the final step captures the named submitter, and the session is bound to the submission record. Output is returned only to the recipient designated on page 1 under the Outbound Communication and Recipient Protocol — not to whoever happens to ask. | Shared |
| Business Associate Contracts | §164.308(b)(1) §164.502(e) |
medTRANS holds executed BAAs covering every layer that touches PHI: the hosting environment (Atlantic.Net), the case-file storage and collaboration platform (Microsoft), and the AI/automation layer used in intake (Anthropic, under Claude Enterprise). medTRANS in turn executes a BAA with the covered entity — the employer's health plan — or with you as its business associate. The chain is documented end to end, with no orphan links and no unpapered AI vendor. | Shared |
| Minimum Necessary | §164.502(b) | We ask for the fields underwriting actually rates on. Do not send Social Security numbers, member addresses beyond ZIP, or named diagnosis detail unless a field specifically calls for it — see "What to strip before you upload" below. | You |
| Breach Notification | §164.410 | medTRANS notifies the covered entity without unreasonable delay and no later than 60 calendar days after discovery of a breach of unsecured PHI, with the content required by §164.410(c). Encryption to NIST-validated standards renders data "unsecured PHI" only if the keys are also compromised. | medTRANS |
The Detail — Expand What You Need
medTRANS does not host PHI on general-purpose commercial web hosting, in a marketing platform, or in a form-builder SaaS. This portal and its underlying case-file storage run on Atlantic.Net HIPAA-Compliant Hosting (HIPAA Business tier) — a dedicated, managed, audited environment purpose-built for ePHI.
What that provider brings to the arrangement:
- A signed Business Associate Agreement. Atlantic.Net executes a BAA for every HIPAA customer, contractually binding them to safeguard PHI. Infrastructure without a BAA is not HIPAA-usable at any price; ours has one.
- Independent HIPAA / HITECH audit. The environment is audited by a third-party CPA firm under the HIPAA attestation standards (AT-C 105/205) covering physical, environmental, technical, and administrative controls.
- SOC 2 Type II and SOC 3 Type II — audited annually. SOC 3 is publicly shareable; SOC 2 Type II is available to you or your auditor under NDA.
- HITRUST-audited data centers, with ISO 27001 certification and PCI DSS alignment on the same infrastructure.
- Managed security services included: managed firewall, intrusion detection and prevention, encrypted VPN administrative access, encrypted storage, log inspection, and file-integrity monitoring.
- Encrypted onsite and offsite backups as standard, supporting the contingency-plan requirement at §164.308(a)(7).
- U.S.-based private data centers owned and operated by the provider, with 24/7/365 staffed support and a redundant network SLA. No offshore processing of your client's PHI.
Atlantic.Net has operated since 1994, is recognized by Gartner in its market guide for cloud service providers to healthcare delivery organizations, and serves Fortune 500 healthcare customers. We chose infrastructure that was already carrying regulated healthcare workloads before we arrived.
The most useful security question a broker can ask is not "is it encrypted" — it is "who reads it." Here is the whole path your client's census takes:
- 1. Receipt. Your upload is received by our automated intake process, which validates the submission, confirms the attachments against the requested tier, and issues your acknowledgement. It does not email your files anywhere.
- 2. Deposit. The intake process deposits the files into a newly created, permissioned SharePoint case-file folder for that employer group. This is the only copy of record.
- 3. Access. That folder is restricted to the Underwriting team and the Executive team. Nobody else in the organization — not sales, not marketing, not administrative staff, not the captive manager's general personnel — is granted access to it.
- 4. Excluded by design. Our developers, infrastructure engineers, and technology vendors build and maintain the platform without PHI access. They do not hold credentials to the case-file folders, and production PHI is never copied into development or test environments. Access exclusion is enforced by permission, not by policy alone.
- 5. AI and automation. Where automation assists intake and normalization, it runs under an enterprise agreement with an executed Business Associate Agreement. Submitted data is not used to train third-party models and is not retained by the AI provider for its own purposes.
- 6. Output. Only the finished Illustration, Indication, or Proposal leaves the case file, and only to the recipient you designate on page 1 under the Outbound Communication and Recipient Protocol.
Net effect: the number of human beings who see your client's PHI is small, named, trained, individually authenticated, and logged. We will tell you the count for your case if you ask.
Any vendor who tells you their hosting provider makes them HIPAA compliant does not understand the rule. Compliant infrastructure is the floor, not the building. HIPAA compliance is determined by the covered entity's and business associate's total adherence to the Privacy and Security Rules — the application, the workforce, and the operating practices, not just the server. Here is the honest division of labor, so you can audit us on the right things:
Atlantic.Net's side of the line: data-center physical security, environmental controls, host-level hardening and patching, managed firewall and IDS/IPS, disk encryption, encrypted backups, network availability, and the audit attestations listed above.
medTRANS's side of the line — and the part you should actually be asking us about:
- Application-layer security of this form: TLS enforcement, upload validation, file-type and size restrictions, malware scanning on upload, protection against injection and traversal attacks.
- Identity and access management: unique named accounts, enforced MFA, role-based authorization, quarterly access reviews, and same-day deprovisioning on termination.
- Application audit logging — who opened which case file and when. The host logs the server; only we can log the underwriter.
- Workforce controls: annual HIPAA training with documented completion, signed confidentiality agreements, background checks, and a sanctions policy for violations (§164.308(a)(1)(ii)(C) and (a)(5)).
- Written policies and a current risk analysis under §164.308(a)(1)(ii)(A), reviewed annually and after material system change.
- Named Privacy Officer and Security Officer (§164.308(a)(2), §164.530(a)).
- Incident response and breach notification procedures, tested, with defined timelines.
- Downstream BAAs with every subcontractor that touches PHI — the hosting provider, the SharePoint case-file platform, TPAs, PBM data feeds, actuarial reviewers, and the AI/automation layer used in intake. All are executed and registered; see the access model below.
- Retention and secure destruction of submissions that never bind.
- Third-party penetration testing and vulnerability scanning of this application, not merely of the host.
We publish this list deliberately. It is the list your client's compliance counsel will ask for, and we would rather hand it to you before you have to ask.
Brokers frequently assume email is acceptable because it is customary. Customary is not the standard; §164.312(e) is. Compare:
| Risk | Email attachment | This portal |
|---|---|---|
| Encryption in transit | Opportunistic at best — TLS between mail servers is not guaranteed and silently downgrades to plaintext | Enforced TLS 1.2+; plaintext connections refused |
| Misdelivery | One autocomplete error sends a full census to the wrong recipient — the leading cause of reportable breaches | No addressee to mistype; the channel has exactly one destination |
| Persistence | Copies live in your sent folder, our inbox, both mail archives, and every mobile device that synced | One controlled copy in the case file, with a defined retention clock |
| Access control | Whoever has mailbox access has the PHI, including delegates and assistants | Role-scoped to the assigned underwriting team |
| Audit trail | Effectively none — you cannot prove who opened it | Immutable log of every access event, producible on request |
| Onward forwarding | Trivial and untracked | Governed by the Outbound Communication and Recipient Protocol |
If your own compliance policy requires secure transmission of ePHI to business associates, this portal is how you satisfy it with us. The submission record we generate also gives you documentary proof of what you sent and when — useful the day someone asks.
The safest PHI is the PHI you never transmit. Underwriting rates on demographics and claims magnitude, not identity. Before uploading:
- Remove Social Security numbers entirely. We never need them. Use the TPA's member or subscriber ID.
- Names are optional. A unique subscriber ID plus a dependent sequence is sufficient for every tier, including Proposal. If your census carries names, you may replace them with IDs — just keep the family key intact so dependents map to subscribers.
- ZIP code only — five digits. Street addresses are not used in rating.
- Keep the family key. This is the one thing we cannot reconstruct. Removing it blocks the case, so de-identify the name column rather than the linkage column.
- Large-claim reports: diagnosis and claimant ID are needed for clinical review; claimant names are not.
- Do not password-protect the files. The channel is already encrypted, and passwords sent separately by email defeat the purpose while creating a second breach vector.
If you are unsure whether a field is needed, upload without it. Underwriting will request it specifically if the tier requires it.
Submissions are retained inside the case file for as long as the underwriting record must be kept, and no longer:
- Bound cases: retained for the policy term plus the applicable statutory and reinsurance retention period, as the underwriting file of record.
- Declined, withdrawn, or non-bound submissions: retained 24 months to support re-quote and audit, then securely destroyed.
- Secure destruction follows NIST SP 800-88 media sanitization guidance; encrypted backups age out on the same schedule rather than persisting indefinitely.
- Early deletion on request. The covered entity — the employer's plan — may request earlier destruction in writing at any time, subject only to legal-hold obligations. We will confirm completion in writing.
- No secondary use. Your client's PHI is used to underwrite your client's case. It is not sold, not licensed, not used to train third-party models, and not repurposed for marketing to the employer or to you.
Aggregate, de-identified experience data may inform medTRANS's manual rating basis. De-identification follows the §164.514(b) Safe Harbor method — all eighteen identifiers removed — so the result is no longer PHI.
Two things worth being clear about, because they protect you:
1. Confirm your authority to disclose. If you are the broker or consultant of record, you are ordinarily a business associate of the employer's group health plan and your disclosure to medTRANS for underwriting is a permitted health-care-operations use — but that rests on your BAA with the plan, not on ours. If you do not hold one, or if you are submitting for a prospect you do not yet represent, get written authorization from the plan sponsor first. We will not ask you to prove it, and we cannot cure its absence.
2. Secure your own end. The encrypted channel starts at your browser. It does not protect a census sitting unencrypted on a laptop desktop, a file shared through a consumer file-sync link, or a spreadsheet forwarded to a colleague after you upload it here. Submit from a managed device, and delete your working copy when the case closes.
If your client's plan requires a direct BAA with medTRANS before any PHI moves, tell us before you upload. We will execute one — typically same business day — and it does not delay your quote.
Security Policy & Procedure Register
medTRANS governs data security under Business Unit 09 — Information Security, Privacy & Business Continuity of the medTRANS Insurance Policy and Procedure Manual. Expand the register to see every policy that governs the handling of your client's PHI, its status, and its citation. Downloadable copies are available for policies in force.
How to read this. Policies marked In force are adopted and available on request. Policies marked In development are drafted and pending executive adoption — we list them rather than hide them, so you can see the full program and its completion state. Nothing below is represented as adopted until it is.
| Citation | Policy | What it governs for your submission | Status |
|---|
The Register PDF lists every policy, its status, its owner, and its HIPAA citation. Individual policy documents and the evidence pack are released by the Privacy Officer on request, subject to NDA where noted.
Evidence We Will Put In Your Hands
Trust is fine; documentation is better. Every item below is available to you, your client, or their auditor. Request them at compliance@completecaptive.com.
Ask for the Privacy Officer or Security Officer by name — we will name them.
This page is informational and describes medTRANS's safeguards as of the date shown in the footer. It is not legal advice and does not substitute for your own organization's HIPAA risk analysis or for the executed Business Associate Agreement, which controls in the event of any conflict.
Request for Stop-Loss Proposal
Fields marked * are required before this can be submitted. One employer group per submission.
Requested Output
Illustration
Non-binding ballpark
- Census: name, gender, DOB, tier, zip
- Current SL/FI data optional
Entry-level manual rate output for early-stage discussions — used to facilitate a conversation on a case that would otherwise be a Deny-to-Quote. Partial data is allowed throughout.
Census
- Name or unique identifier
- Gender (unstated defaults to Female)
- Date of birth
- Coverage tier election
- Zip code
Current Policy / Rates
- Optional
Incumbent Renewal Offer
- Optional
Requested Coverage
- Deductible level: optional
- Contract duration: optional (defaults to 12/18)
TPA / PBM / Network
- Optional
Indication
Non-binding, near-final
- Full census incl. plan elections
- Current SL/FI data required for rating
A near-bindable rate contingent on substantially complete data. Non-binding, but designed to drive the case toward a full Proposal.
Census
- Full employee census with plan elections
- Dependents, if available
Current Policy / Rates
- Required for rating — current specific deductible & aggregating specific deductible (if applicable), current specific/aggregate premiums, aggregate factors — or, if fully insured, current premiums by tier and plan
Incumbent Renewal Offer
- Preferred
Requested Coverage
- Deductible level: required, up to 3 levels
- Contract duration: required
Opportunity Details
- Business name & corporate address
- Desired TPA / PBM / managed care network
- Recipient of the output (consultant or insured)
TPA / PBM / Network
- Preferred
Proposal
Binding offer
- Full census + dependents
- 9-mo. claims, renewal & clinical review required
A fully underwritten, bindable offer — medTRANS's offer to bind an insurance policy between the client's captive and the client. Requires the complete underwriting dataset, and every Proposal undergoes clinical review before issuance.
Census
- Complete, accurate census with dependents (if available), plan and tier elections
- Average employee age must be under 50.0 as of the effective date, or the case cannot proceed to Proposal
Current Policy / Rates
- Required & verified — current specific deductible and lasers, aggregating specific deductible (if applicable), current premiums, aggregate factors and rates — or current fully-insured premiums by tier and plan
Rating Review
- Self-funded: aggregate report through the current 9th month, plus prior period's completed report
- Fully insured: premium-to-claims, month over month, current and prior period
Clinical Review (required before issuance)
- Self-funded: detailed Rx claims, pended/denied-yet-payable claims, 50% large-claim report, clinical notes on triggered members
- Fully insured: same items, discretionary / as available
Incumbent Renewal Offer
- Required
Opportunity Details
- Business name, address, industry
- Current renewal offer from incumbent carrier
- Desired TPA / PBM / vendor programs
- Recipient of the output
Requested Coverage
- Deductible level: required, up to 3 levels
- Contract term & duration: required
- Number of desired tiers
Data Supplier — Broker / Consultant
Per the medTRANS Outbound Communication and Recipient Protocol, submitting data does not by itself confer Primary Relationship status.
Insured Information
Insured Profile
Coverage Detail
Current / To Be Proposed. At least one of Incurred/Run-out or Run-In/Incurred is required.
Funding & Contract Basis
† Required: at least one of the two rows above (Incurred/Run-out OR Run-In/Incurred), Current column only.
Specific & Aggregate
Coverage Options
Health Plan Service Provider Stack
Select or type the provider in place today and desired for this submission. Use "Other/Unlisted" if not shown.
Requested Coverage Details
Supporting Documentation
Drag files onto a zone or click Browse. All PHI/PII is transmitted through this secure, encrypted upload channel — never as an email attachment.