Do entities that transport PHI but do not access use or disclose the information are they business associates?

Entities that transport Protected Health Information (PHI) but do not access, use, or disclose the information typically do not qualify as business associates under HIPAA. Business associates are defined as those who perform certain functions or activities on behalf of a covered entity that involve the use or disclosure of PHI. If the entity is merely providing transportation services without any access to the information, they may be considered a mere conduit and not a business associate. However, it's important for covered entities to ensure that any agreements reflect this status.