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CAS-004 Practice Question: A healthtech startup is developing a mobile app…

A healthtech startup is developing a mobile app that collects PHI. They plan to use a third-party cloud provider for data storage. What is the most critical compliance requirement before signing the contract?

⚠ Common exam trap

CompTIA often tests the distinction between contractual compliance (BAA) and technical controls (encryption, SOC reports), leading candidates to prioritize security measures over the mandatory legal agreement required by HIPAA.

Answer choices

Why each option matters

Answer the question above first, then reveal the full breakdown to understand why each option is right or wrong.

Correct answer & explanation

✓

Execute a Business Associate Agreement (BAA) with the provider

Under HIPAA, a Business Associate Agreement (BAA) is a mandatory contract that ensures the third-party cloud provider (a business associate) will safeguard Protected Health Information (PHI). Without a BAA, the startup would be in direct violation of HIPAA's Privacy and Security Rules, regardless of other security measures. This requirement is non-negotiable before any PHI is shared or stored by the provider.

Answer analysis

Option-by-option breakdown

For each option: why learners choose it and why it is or isn't the right answer here.

  • ✗

    Verify the provider's data center locations comply with data residency laws

    Why it's wrong here

    Data residency affects where PHI is stored but does not create the legal obligation governing the provider's handling of PHI; without a Business Associate Agreement the disclosure itself is non-compliant. It is tempting for jurisdictional compliance, which suits EU or sector-specific localisation rules, but HIPAA mandates the BAA first.

  • ✓

    Execute a Business Associate Agreement (BAA) with the provider

    Why this is correct

    HIPAA requires a Business Associate Agreement before a third party creates, receives or stores PHI, contractually binding the cloud provider to safeguards, breach notification and use restrictions. This satisfies the stem's requirement for the most critical compliance step preceding contract signature.

  • ✗

    Review the provider's SOC 2 Type II report

    Why it's wrong here

    SOC 2 Type II attests security controls over time but does not satisfy HIPAA's requirement for a signed Business Associate Agreement before PHI is disclosed to the provider. It is tempting as vendor due diligence evidence, which suits general security assurance, yet the stem demands the BAA as the critical pre-contract requirement.

  • ✗

    Ensure all data is encrypted at rest and in transit

    Why it's wrong here

    Encryption at rest and in transit is a safeguard, not the contractual prerequisite; HIPAA requires a Business Associate Agreement before PHI is shared with the provider, and encryption alone leaves that obligation unmet. It is tempting as a core technical control, which suits breach-risk reduction, but the stem asks for the critical pre-contract compliance requirement.

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JA

Written by Johnson Ajibi, MSc IT Security

Senior Network & Security Engineer · founder of Courseiva

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