Focusing on the data help clarify this. This is a negligently simple explanation, but: HIPAA regulates identifiable patient data that touches a US-regulated ins

Focusing on the data help clarify this. This is a negligently simple explanation, but: HIPAA regulates identifiable patient data that touches a US-regulated insurance transaction somewhere in its lifecycle. If you're in the US, but working with only international healthcare providers and international patients, HIPAA is less likely to apply. You may have other privacy laws and regulations to deal with, however, especially in Europe.