Can each member share to their provider and payer, get a doctor-facing dashboard, and feed in Apple Health / pulse-ox / blood-pressure data — and is that an API or a structural upgrade?
The sharing and biometrics features are easy to build on FHIR. But the moment you store individual biometrics and share identified clinical data with a provider, that data becomes PHI. That creates a new protected zone, which changes your HIPAA posture, requires signed BAAs with your infrastructure, and moves you to a higher (HIPAA-eligible) server tier. It does not have to expand FERPA if you firewall it.
Each consented member can share their FHIR record — engagement, Certified Patient score, biometrics — with their provider or payer. Patient-mediated exchange is exactly what FHIR + SMART was built for.
A provider view reads that member's shared FHIR data — the "prepared patient" snapshot before the visit. This is Dr. Rob's original vision, delivered through a SMART-on-FHIR provider launch.
Nothing shares by default. The member opts in per recipient, and can revoke. Consent is recorded and auditable — the control that keeps this lawful.
Terra (already on the FFH roadmap) connects 500+ devices including Apple Health, normalizes the data, and we map it to standard FHIR vital-sign Observations — the same resource type as engagement, so it flows into the same engine and can be shared to the doctor.
| Device data | Source | FHIR resource |
|---|---|---|
| Steps / activity | Apple Health, Fitbit, Garmin… | Observation (activity) |
| Heart rate / HRV | Watch, Whoop, Oura | Observation (vital-signs) |
| Pulse ox (SpO₂) | Watch, pulse oximeter | Observation (oxygen-saturation) |
| Blood pressure | Connected BP cuff | Observation (blood-pressure) |
Coins can reward hitting device-tracked goals (e.g., 10k steps), closing the loop between the game and real physiology.
| Area | Impact | What to do |
|---|---|---|
| HIPAA scope expands | The biometric + clinical-sharing module holds PHI. You can no longer say "mostly not PHI" for that module. | Treat it as a HIPAA zone: consent, encryption, audit logging, minimum-necessary. |
| Infrastructure BAAs required | Your hosts must sign BAAs and run HIPAA-eligible tiers. | Supabase HIPAA add-on (Team plan), Vercel HIPAA BAA (now on Pro), Terra BAA. Confirm current terms at contracting. |
| Server / cost tier jumps | Moves off the ~$540–640/mo target for this module. | Budget the HIPAA tier — see below. |
| FERPA contained | Does NOT have to expand — health/biometric sharing is a health feature, not the student education record. | Firewall it from education data; run adults-first on consent. |
| Minors / COPPA extra care | Children's biometrics need verifiable parental consent and stay out of the education record. | Launch on the consented adult population first; add minors later with the consent flow. |
| De-identified analytics unchanged | The payer/community/grant reporting stays de-identified and low-risk. | Keep it separate from the PHI zone (below). |
Supabase HIPAA compliance is a paid add-on available on the Team plan (~$599/mo) and above with a signed BAA. Vercel now offers HIPAA BAAs on Pro. Terra signs a BAA for its healthcare tier. So the PHI module realistically adds on the order of ~$600+/mo over the current lean stack — the concrete answer to "does it affect our server levels?": yes, for this module.
Same platform, two governance tiers. The de-identified product you're already selling doesn't inherit the PHI compliance burden — only the new sharing module does.
Build member sharing + biometrics as a distinct, opt-in Personal Health Record / Prepared Patient module on HIPAA-eligible infrastructure with signed BAAs, consent management, and audit logging — kept firewalled from both the education record (FERPA) and the de-identified analytics product. It's worth the server-tier cost: it's Dr. Rob's prepared-patient vision, it deepens the payer and provider relationship, and the compliance bar itself becomes a competitive moat. Turn it on per consented member, adults first.
What changes in your pitch: for this module you say "FFH operates a HIPAA-compliant Personal Health zone under BAAs, with member consent and audit" — a stronger claim, and a real obligation, so it ships as its own compliance-grade release, not a toggle on the existing app.
Supabase HIPAA add-on & Team-plan requirement: supabase.com/docs/guides/security/hipaa-compliance, supabase.com/docs/guides/platform/hipaa-projects. Vercel HIPAA BAAs on Pro: vercel.com/changelog/hipaa-baas-are-now-available-to-pro-teams, vercel.com/docs/security/compliance. Terra wearable/Apple Health & healthcare: tryterra.co, tryterra.co/integrations/apple-health.