Paper-to-paper, non-digital fax communications are not considered electronic transmissions when the information being exchanged did not exist in electronic format prior to the fax transmission. Therefore, if a healthcare provider only transmits health information for a HIPAA transaction by paper-to-paper non-digital fax, the healthcare provider is not a Covered Entity. However, as well as paper-to-paper faxes being a poor data security practice, if the faxed health information was stored electronically prior to transmission (i.e., saved on a workstation) or any other electronic communication channel is used for any other HIPAA transaction, the healthcare provider is a Covered Entity, and all transmissions are subject to HIPAA compliance requirements.