Hello Alex Tran,
Welcome to Microsoft Q&A and Thank you for reaching out.
The BAA is part of the Microsoft Online Services Data Protection Addendum (DPA). BAA is already in effect automatically for (EA / MCA / CSP)
Since you are consuming OpenAI, Anthropic, and Gemini through Azure AI Foundry, there is no separate BAA request per model.
The HIPAA Business Associate Agreement is provided by Azure itself via the Microsoft Products and Services Data Protection Addendum (DPA) and applies automatically for customers on Enterprise Agreement, Microsoft Customer Agreement, or CSP.
To proceed, please
- Confirm your Azure subscription type if it falls under (EA / MCA / CSP).
- Retain the DPA / HIPAA documentation from the Service Trust Portal
- Deploy the solution using HIPAA‑aligned configurations (U.S. regions, encryption, RBAC, private networking)
There is no additional BAA signing required unless models are accessed outside Azure.
References
HIPAA - Azure Compliance | Microsoft Learn
Licensing Documents
Regulatory Compliance details for HIPAA HITRUST - Azure Policy | Microsoft Learn
Please let me know if you have any questions.
Thank you!
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