Short answer: Google will not sign a Business Associate Agreement for Google Analytics, and says so in its own documentation. If your website collects, displays or routes protected health information, that rules GA4 out on those pages. The replacements that will actually sign a BAA are Ghost Metrics, Piwik PRO, Freshpaint, Adobe Customer Journey Analytics, Celebrus, and a handful of product-analytics tools built for software rather than health systems. The differences that matter are which plan the BAA comes with, whether pricing is public, and whether the vendor hosts your data or hands you a server to harden yourself.
Why people go looking for this in the first place
Google's own support documentation says it plainly:
"Google makes no representations that Google Analytics satisfies HIPAA requirements and does not offer Business Associate Agreements in connection with this service."
The same page tells covered entities they "must not use Google Analytics in any way that implicates Google's access to, or collection of, PHI, and may only use Google Analytics on pages that are not HIPAA-covered."
That is not a gap Google plans to close. It is a product decision, and it has been consistent for years. We go through the whole question, including every workaround people try, in Is Google Analytics HIPAA compliant?
Meta's Business Tools Terms take the same shape from the other direction, prohibiting the sharing of data that "includes or is based on, directly or otherwise, health information."
So the question is not whether you can configure your way into compliance with a vendor that has declined to be your business associate. The question is what you replace it with.
What the enforcement record actually says
Two things get confused here constantly, and getting them straight will save you an argument with your general counsel.
The June 2024 ruling did not clear this. In AHA v. Becerra (N.D. Tex., June 20, 2024), the court vacated one specific piece of the HHS OCR bulletin on tracking technologies: the theory that an IP address combined with a visit to an unauthenticated public health page is itself protected information. A permanent injunction was denied. HHS filed a notice of appeal on August 19, 2024 and withdrew it about ten days later, so no appellate ruling exists. Everything else in the bulletin is still posted, including the guidance on authenticated pages and on vendors needing a BAA.
The money never came from HIPAA anyway. Almost every large payment in this area came from state wiretap statutes, medical confidentiality laws, common-law privacy claims and the FTC's deception theory. The AHA ruling touched none of those.
| Matter | Outcome | What it was | Detail |
|---|---|---|---|
| FTC/DOJ v. GoodRxFeb 2023 | $1.5M | Civil penalty | Stipulated order under the FTC Act and the Health Breach Notification Rule. |
| FTC v. BetterHelpMar 2023, final Jul 2023 | $7.8M | Consumer refunds | FTC Act Section 5. The FTC was explicit this is not a civil penalty. |
| FTC and HHS joint warning letterJul 20, 2023 | n/a | No penalty | Sent to roughly 130 hospital systems and telehealth providers, naming the Meta Pixel and Google Analytics. |
| FTC/DOJ v. CerebralApr 2024 | $5.1M + $2M | Refunds and penalty | Not a "$7 million fine." Refunds for cancellation practices, plus a $10M civil penalty suspended to $2M. |
| FTC/DOJ v. MonumentApr 2024 | $2.5M, suspended | Paid nothing | The penalty was fully suspended. Nothing was paid. |
| Novant HealthJun 2024 | $6.66M | Class settlement | Meta Pixel on the website and MyChart. |
| Advocate Aurora HealthJul 2024 | $12.225M | Class settlement | Meta Pixel and Google Analytics. |
| Eisenhower Medical CenterApproved Oct 2025 | $875,000 | Class settlement | Includes a two-year ban on the Meta Pixel and other tracking tools. |
| Aspen DentalApproved Oct 2025 | About $18.47M | Class settlement | Meta Pixel and Google tools on booking. |
| Sutter HealthMar 6, 2026 | $21.5M | Class settlement | Google Analytics and Meta Pixel on the patient portal login, 2015 to 2020 conduct. |
| Kaiser PermanenteJul 22, 2026 | $46M to $47.5M | Class settlement | Trackers sent data to Google, Microsoft Bing and X, not Meta. |
| Duke University Health SystemAug 27, 2026 | $3,743,600 | Class settlement | Final approval granted. |
| Allina Health SystemHearing Sep 24, 2026 | $12.5M | Proposed | Meta and Google pixels, brought under the federal wiretap statute and Minnesota health records law. Outcome unconfirmed. |
| FTC, Utah and L.A. County v. Hims & HersFiled Jul 29, 2026 | None yet | Pending | Allegations only. No HIPAA or HBNR count. Hims calls it baseless. |
Several hearings on the calendar right now are worth watching, because the forward-looking terms are the part that changes what a marketing department is allowed to install: Mount Sinai Medical Center of Florida (October 13, 2026), LifeStance Health (October 16, 2026, $3,027,874, five years of using only tools fully compliant with the HIPAA Rules), Bayhealth (October 29, 2026), Concord Hospital (November 3, 2026, $800,000, a matter that named Google Analytics and Geonetric pixels), and Penn Medicine (November 12, 2026, up to $9.25 million, two years with no analytics or advertising technology unless a web governance committee approves it).
None of this is legal advice, and none of it tells you what your organization's exposure is. That is a conversation for your privacy officer and your counsel. What it does tell you is which direction the risk is moving.
The three real options, not ten
Every roundup on this topic lists tools. Almost none of them names the three architectural choices underneath, and the choice you make there determines which tools are even on your list.
Replace it. Take Google Analytics off the site and put a platform that signs a BAA in its place. One script swap. You get the reporting back immediately and you stop sending anything to Google. This is what most health systems end up doing.
Wrap it. Keep GA4 and put a BAA-backed privacy layer in front of it that strips or blocks what it decides is PHI before it reaches Google. Freshpaint, Geonetric's Privacy Filter and Unlock Health sell this. It is genuinely easier politically, because nobody has to give up their Google Ads workflow.
It is also a bet. Google's own text says covered entities may use Analytics "only on pages that are not HIPAA-covered." A filter changes what reaches Google. It does not change what Google says about the product, and it does not make Google your business associate. Concord Hospital's proposed $800,000 settlement named both Google Analytics and Geonetric pixels. That is one matter, not a verdict on the category, but it is worth knowing before you sign.
Turn it off. Some organizations pull every tag and run blind. It is compliant and it is expensive: you are now buying paid search without knowing which pages convert, and the usual ending is that something quietly goes back on the site six weeks later because leadership wants its numbers. Proving marketing works without tracking individuals is the better version of this conversation.
One thing worth saying about where the exposure actually sits. Most of the public attention has been on the Meta Pixel, and after three years of litigation it has largely come off healthcare sites. The Google stack is the tag that stayed, usually GA4 paired with Google Ads conversion or remarketing tags, and it is the one named in the Sutter, Kaiser, Advocate Aurora, Allina and Concord matters above. If you are auditing your own site, start there rather than with Meta.
The alternatives, with the BAA and the price attached
This is the table the other roundups will not print. "Signs a BAA" is not a yes or no. It matters enormously which plan the BAA comes with, because on several of these platforms the answer is "the one with no published price."
| Tool | Signs a BAA? On which plan | Published price | Hosting | Built for |
|---|---|---|---|---|
| Ghost MetricsThat's us | YesEvery plan, including StarterStandard BAA on every plan. Minor redlines on Premium, custom terms on Enterprise. | $299 / $399 / $499 per month, Enterprise custom | US-hosted, each customer's data logically isolated | Healthcare marketing sites |
| Piwik PRO | Higher tierHealthcare Enterprise, from $30,000 a yearIts pricing page labels the tier "Healthcare Enterprise (includes BAA)" and marks the plain Enterprise tier "BAA not included." Also signs during the free trial. | Healthcare Enterprise from $30,000/yr; Enterprise from $25,000/yr without the BAA | Cloud, US option | General privacy-first analytics |
| Freshpaint | YesTier not publishedSays plainly that it signs. Which plans include it is not stated. | None published. "Talk to sales" | Vendor cloud | Keeping GA4 and ad tools in place |
| Adobe Customer Journey Analytics | Higher tierEnterprise | None published | Adobe cloud | Enterprise data teams |
| Celebrus | YesTier not statedStates it is "happy to sign Business Associate Agreements." | None published | Vendor cloud | First-party data capture |
| Matomo | NoNoneMatomo's own FAQ says Matomo Cloud is not HIPAA compliant. On-Premise, compliance is the operator's job and the BAA is with your host. | On-premise free to about €275/mo; Cloud from about €29/mo | Self-hosted or Matomo Cloud | General analytics |
| Geonetric Privacy Filter | YesFor the filter; tier not stated | None published | In front of your GA4 | Hospital web agency clients |
| Unlock Health (Privacy Pro) | YesTier not stated | None published | Vendor platform | Agency-embedded healthcare marketing |
| Server-side GTM hosts (Stape and similar) | YesFor the relay onlyThe BAA binds the relay host, not Google, where the data still lands. | From about $20/mo | Your relay, Google's destination | Tag relay, not compliance |
| Mixpanel | Higher tierEnterprise | Enterprise custom | Vendor cloud | Product teams |
| Amplitude | Higher tierPaid tiers | Custom | Vendor cloud | Product teams |
| PostHog | Higher tierPaid tiers | Usage-based | Vendor cloud | Product and engineering teams |
| Microsoft Clarity, Hotjar, Fathom, Plausible | NoNoneNo BAA and no HIPAA statement. | Free to about $45/mo | Vendor cloud | General web and session analytics |
Four things fall out of that table.
Piwik PRO is a capable GA replacement and the one competitor on this list that genuinely competes on features. Its pricing page, read October 6, 2026, shows two tiers: Healthcare Enterprise, from $30,000 a year, which includes the BAA, and Enterprise, from $25,000 a year, marked "BAA not included." Credit where it is due: that is clearer than the custom-quote answer most vendors give. It is also a floor of about $2,500 a month before the conversation starts. If you are a two-hospital system with a marketing budget measured in the low thousands, "yes, we sign BAAs" and "yes, we will sign one with you at a price you can pay" are not the same sentence. Ask for the plan name and the price in writing.
Server-side tagging is the most common suggestion in this category and the most misunderstood. A BAA with the company hosting your tag relay covers the relay. The data still lands in Google Analytics, and Google's text about HIPAA-covered pages has not changed. Server-side tagging won't save you has the long version.
Four of the pages currently ranking on these queries put Matomo in a compliant column or say it offers a BAA. Matomo's own FAQ says the opposite: the Cloud service is not HIPAA compliant, and no BAA is signed because Matomo does not host or access self-hosted data. Self-hosting is a legitimate path if you have the infrastructure team for it, and it moves the BAA to whoever hosts your server rather than removing it.
Mixpanel, Amplitude and PostHog all sign BAAs on paid tiers. They are event-first tools designed for software product teams. If your job is to report on service-line landing pages, campaign attribution and appointment-request funnels for a hospital marketing committee, you will spend the first month rebuilding things that a web analytics platform gives you on day one.
Where Ghost Metrics fits
Ghost Metrics is website analytics for healthcare organizations. We sign a Business Associate Agreement with every customer on every plan, including the $299 one. Each customer's data is logically isolated on US-hosted infrastructure, and identifiers are stripped before storage. Nothing is shared, sold or used for advertising, because there is no advertising business on the other end of it. We hold SOC 2 Type II.
What is in the product on every plan: real-time visitors, acquisition and campaign reporting, custom events for appointment requests and form submissions, conversions and goals, and a reporting API. Premium and Enterprise add funnels, heatmaps and session recording, A/B testing, cohorts, form analytics and a custom report builder. Also in the product: a tag manager with live, staging and dev environments, bot and cloud-IP filtering, and rollup reporting across sites for groups and systems. How the hosting, encryption and audit logging work is on the security page, and the data terms are in our DPA.
Pricing is on the website because hiding it wastes everyone's time:
| Plan | Price per month | Actions per month | Websites | Users |
|---|---|---|---|---|
| Starter | $299 | 10,000 | 1 | 1 |
| Standard | $399 | 250,000 | 1 | 5 |
| Premium | $499 | 1,000,000 | 5 | 10 |
| Enterprise | Custom | 1,000,000+ | 5+ | Unlimited |
The embed is a standard JavaScript snippet, so the swap itself is an afternoon, not a project. There is no free trial, and that is deliberate: a BAA has to be signed before real traffic flows, so we demo on a live instance instead. Full detail is on the pricing page and the product page.
Where we are not the answer: if you are a software company that needs product analytics on an application, buy a product analytics tool. If you are committed to keeping GA4 and the Google Ads stack and want a filter in front of it, that is Freshpaint's pitch and they do it well, and you should read Section 2 before you decide.
What you actually lose when you turn GA4 off
Nobody else on this result set will tell you this, so here it is straight.
This is the real one. GA4 conversions flow into Google Ads for smart bidding. Leaving GA4 means rebuilding conversion tracking through Google Ads' own tag or through offline conversion imports, and both of those have their own HIPAA questions that your privacy officer should look at before you switch anything on.
Query-level data stitched to landing pages inside the same interface. Search Console itself still works and still shows you queries. The convenience of the join is what goes.
Losing these on healthcare pages is arguably the point, since demographic inference plus health-topic pages is the exact pattern the settlements are about.
A reporting API covers this, but somebody has to rebuild the dashboards.
sessions, users, acquisition channels, campaign attribution, landing page performance, funnels, goals, events, site search, device and geography breakdowns, and year-over-year trend once you have a year.
Export it before you turn anything off. You will want the year-over-year comparison and you cannot get it back later.
How to choose in one sitting
Six steps, in order. Most teams can do the first three in an afternoon and the rest inside a week.
- 01Find out what is actually running.
Load your appointment request page, your top three condition pages and your portal login with the network tab open. Homepages lie; the exposure is usually deeper in. The ten-minute audit linked below walks through it.
- 02Ask each vendor one question: will you sign a BAA on the plan I can afford?
Write down the plan name and the price, not the yes.
- 03Decide replace, wrap or off.
Section 2. If nobody in the room can say why you picked one, you have not picked.
- 04Check the forward-looking terms if you have settled anything.
Several 2025 and 2026 settlements restrict which tools you may install for two to five years. If that is you, the restriction, not the budget, picks your vendor.
- 05Export your GA4 history before you switch.
You will want the year-over-year comparison and you cannot get it back later.
- 06Send the shortlist to your privacy officer and counsel before you sign.
Every vendor on this page, including us, is telling you what its product does. None of us can tell you what your obligations are.
Frequently asked questions
Is Google Analytics HIPAA compliant?
No. Google states that it makes no representations that Google Analytics satisfies HIPAA requirements and that it does not offer Business Associate Agreements for the service. It also says covered entities may use Analytics only on pages that are not HIPAA-covered. The full answer, including every workaround people try, is on our Google Analytics page.
Does Google sign a BAA for Google Analytics?
No. Google signs BAAs for some Google Workspace and Google Cloud services. Google Analytics is not one of them, and Google says so in its own documentation.
Can IP anonymization make GA4 HIPAA compliant?
It does not change the BAA question, which is the one that matters first. Anonymizing an IP address does not make Google your business associate, and the other identifiers a page can pass along (URLs, event parameters, click IDs, existing cookies) are untouched by it.
Is Matomo HIPAA compliant?
Matomo's own FAQ states that Matomo Cloud is not HIPAA compliant, and that no BAA is signed with Matomo because Matomo does not host or access the data in a self-hosted deployment. For Matomo On-Premise, Matomo's position is that compliance is the operator's responsibility, which means the hosting, encryption, access control, audit logging and the BAA with your host are all yours to build and sign. Self-hosting an open-source analytics tool is a valid path if you have the infrastructure team for it.
What is the cheapest analytics platform that will sign a BAA?
Of the platforms that publish a price and include the BAA on that plan, Ghost Metrics at $299 a month is the lowest we know of. Piwik PRO publishes a floor of $30,000 a year for its BAA tier. Several competitors sign only at custom-quoted tiers and publish no price at all, which is why the table in Section 3 lists the plan alongside the answer.
Will I lose Google Ads conversion tracking if I leave GA4?
The automatic GA4-to-Google-Ads conversion import goes away, yes. You can rebuild conversion tracking through Google Ads directly or through offline conversion imports, and both routes raise their own questions worth putting to your privacy officer. Section 5 lists what else changes.
Where to go next
- The full category comparison, thirteen tools: the 2026 buyer's guide
- The Google question in full: Is Google Analytics HIPAA compliant?
- Audit your own site in ten minutes: HIPAA guide and audit
- What a PHI leak looks like in a network log: Anatomy of a PHI leak
- The settlements, read closely: Allina and Atrium pixel settlements
- See it on a live instance: book a demo
This page is general information about HIPAA and website analytics, not legal advice. Settlement figures and vendor terms were checked against primary sources on October 6, 2026.