LunaHealth Technologies, Inc. dba LunaBill | Trust Center
LunaBill Trust Center
Our agents make payer calls, check portals, and work denials on behalf of hospitals, which means they handle protected health information all day. Below is our SOC 2 Type 2 report, our HIPAA program, the controls we run, and the vendors that touch customer data.
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Resources

SOC 2 Type 2 Report

Independent SOC 2 Type 2 examination (Security) covering Dec 22, 2025 to Mar 22, 2026. Unqualified opinion, no exceptions noted.

SOC 2 Type 1 Report

SOC 2 Type 1 report as of December 22, 2025, issued by an independent CPA firm.

Penetration Test Summary

Executive summary of the June 2026 third-party web application and API penetration test by Casco. No critical or high findings; all findings have been remediated.

HIPAA Security Risk Assessment

Most recent HIPAA security risk assessment for LunaBill systems that handle PHI.

Access Control and Termination Policy

Least-privilege access to LunaBill systems and data, and how access is granted, reviewed, and removed at termination.

AI Governance and Responsible AI Policy

Governance, permitted scope, accountability, and PHI protections for LunaBill's AI voice agents and LLM services.

Baseline Hardening Policy

Network, patching, and vulnerability management baseline for LunaBill infrastructure.

Board of Directors Charter

Roles, composition, and oversight responsibilities of the LunaBill board, including compliance and security oversight.

Breach Notification Policy

How LunaBill identifies, reports, and manages PHI breaches under the HIPAA Breach Notification Rule.

Business Continuity and Disaster Recovery Policy

How LunaBill maintains critical operations and recovers service after a disruption.

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FAQs

LunaBill has a SOC 2 Type 2 report (Security criteria) from an independent CPA firm, issued July 2026. The opinion was unqualified and the auditors noted no exceptions. Request the full report under Resources.
LunaBill is a business associate under HIPAA and signs a BAA with every hospital and health system it works with. We also hold BAAs with every subprocessor that handles PHI on our behalf: Google Cloud Platform, Anthropic, and Telnyx. We run a HIPAA security program, complete a security risk assessment on a regular cycle, and limit PHI access to staff whose role requires it.
Google Cloud Platform, US regions only. Data is encrypted in transit and at rest. Admin access is restricted and logged, and the environment is checked continuously against our SOC 2 controls through Secureframe. You can see the live control status in the Monitoring section.
An agent gets the fields it needs for the task in front of it (member ID, date of service, claim number) and nothing more. Call recordings and transcripts are encrypted at rest and only reachable by authorized staff. They are retained only for the life of the customer contract and deleted when the contract ends. The model provider we use, Anthropic, is under a Business Associate Agreement and does not train on our customers' data.
Both. An outside firm runs a penetration test, and we scan for vulnerabilities on an ongoing basis with a written patch process behind it. The executive summary of the latest test is under Resources.
Click Request all documents at the top of the Resources section. For a questionnaire or anything not answered here, write to [email protected].

Subprocessors

Google Cloud Platform

Cloud hosting, compute, storage, and databases for the LunaBill platform. Covered by a Business Associate Agreement.

Data location: United States

Anthropic

Large language model inference for agent reasoning and document understanding. Covered by a Business Associate Agreement. Customer data is not used for model training.

Data location: United States

Telnyx

Telephony carrier for outbound and inbound payer calls made by LunaBill voice agents. Covered by a Business Associate Agreement.

Data location: United States

Monitoring

Continuously monitored by Secureframe
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Compliance

HIPAA

LunaBill operates as a HIPAA business associate, signs BAAs with customers, and maintains a HIPAA security program with regular risk assessments.

SOC 2

SOC 2 Type 2 (Security) report issued July 2026. Unqualified opinion, no exceptions noted.

Monitoring

Change Management

Secure Development Policy
A Secure Development Policy defines the requirements for secure software and system development and maintenance.
Baseline Configurations
Baseline configurations and codebases for production infrastructure, systems, and applications are securely managed.
Production Data Use is Restricted
Production data is not used in the development and testing environments, unless required for debugging customer issues.
Approval for System Changes
System changes are approved by at least 1 independent person prior to deployment into production.
Change Management Policy
A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.
Segregation of Environments
Development, staging, and production environments are segregated.
Configuration and Asset Management Policy
A Configuration and Asset Management Policy governs configurations for new sensitive systems

Availability

Uptime and Availability Monitoring
System tools monitors for uptime and availability based on predetermined criteria.
Backup Restoration Testing
Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups.
Business Continuity and Disaster Recovery Policy
Business Continuity and Disaster Recovery Policy governs required processes for restoring the service or supporting infrastructure after suffering a disaster or disruption.
Automated Backup Process
Full backups are performed and retained in accordance with the Business Continuity and Disaster Recovery Policy.
Testing the Business Continuity and Disaster Recovery Plan
The Business Continuity and Disaster Recovery Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Business Continuity and Disaster Recovery Plan based on the test results.

Organizational Management

Independent Advisor
The board of directors or equivalent entity function includes senior management and external advisors, who are independent from the company's operations. An information security team has also been established to govern cybersecurity.
Roles and Responsibilities
Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.
Performance Reviews
Internal personnel are evaluated via a formal performance review at least annually
Code of Conduct
A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.
Disciplinary Action
Personnel who violate information security policies are subject to disciplinary action and such disciplinary action is clearly documented in one or more policies.
Information Security Policy
An Information Security Policy establishes the security requirements for maintaining the security, confidentiality, integrity, and availability of applications, systems, infrastructure, and data.
Cybersecurity Insurance
Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events.
Performance Review Policy
A Performance Review Policy provides personnel context and transparency into their performance and career development processes.
Organizational Chart
Management maintains a formal organizational chart to clearly identify positions of authority and the lines of communication, and publishes the organizational chart to internal personnel.
Internal Control Monitoring
A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.
Advisor Meetings on Security
Senior management and/or board of directors meets at least annually to review business goals, company initiatives, resource needs, risk management activities, and other internal/external matters. The information security team meets at least annually to discuss security risks, roles & responsibilities, controls, changes, audit results and/or other matters as necessary.
Acceptable Use Policy
An Acceptable Use Policy defines standards for appropriate and secure use of company hardware and electronic systems including storage media, communication tools and internet access.
New Hire Screening
Hiring managers screen new hires or internal transfers to assess their qualifications, experience, and competency to fulfill their responsibilities. New hires sign confidentiality agreements or equivalents upon hire.
Information Security Program Review
Management is responsible for the design, implementation, and management of the organization’s security policies and procedures. The policies and procedures are reviewed by management at least annually.
Internal Control Policy
An Internal Control Policy identifies how a system of controls should be maintained to safeguard assets, promote operational efficiency, and encourage adherence to prescribed managerial policies.

Confidentiality

Access to Customer Data is Restricted
Access to, erasure of, or destruction of customer data is restricted to personnel that need access based on the principle of least privilege.
Disposal of Customer Data
Upon customer request, Company requires that data that is no longer needed from databases and other file stores is removed in accordance with agreed-upon customer requirements.
Data Retention and Disposal Policy
A Data Retention and Disposal Policy specifies how customer data is to be retained and disposed of based on compliance requirements and contractual obligations.
Data Classification Policy
A Data Classification Policy details the security and handling protocols for sensitive data.
Retention of Customer Data
Procedures are in place to retain customer data based on agreed-upon customer requirements or in line with information security policies.

Vulnerability Management

Third-Party Penetration Test
A 3rd party is engaged to conduct a network and application penetration test of the production environment at least annually. Critical and high-risk findings are tracked through resolution.
Vulnerability and Patch Management Policy
A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities.

Incident Response

Tracking a Security Incident
Identified incidents are documented, tracked, and analyzed according to the Incident Response Plan.
Incident Response Plan
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.
Incident Response Plan Testing
The Incident Response Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Incident Response Plan based on the test results.
Lessons Learned
After any identified security incident has been resolved, management provides a "Lessons Learned" document to the team in order to continually improve security and operations.

Risk Assessment

Risk Register
A risk register is maintained, which records the risk mitigation strategies for identified risks, and the development or modification of controls consistent with the risk mitigation strategy.
Vendor Risk Assessment
New vendors are assessed in accordance with the Vendor Risk Management Policy prior to engaging with the vendor. Reassessment occurs at least annually.
Risk Assessment
Formal risk assessments are performed, which includes the identification of relevant internal and external threats related to security, availability, confidentiality, and fraud, and an analysis of risks associated with those threats.
Vendor Due Diligence Review
Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.
Risk Assessment and Treatment Policy
A Risk Assessment and Treatment Policy governs the process for conducting risk assessments to account for threats, vulnerabilities, likelihood, and impact with respect to assets, team members, customers, vendors, suppliers, and partners. Risk tolerance and strategies are also defined in the policy.
Vendor Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.

Network Security

Logging and Monitoring for Threats
Logging and monitoring software is used to collect data from infrastructure to detect potential security threats, unusual system activity, and monitor system performance, as applicable.
Network Security Policy
A Network Security Policy identifies the requirements for protecting information and systems within and across networks.
Automated Alerting for Security Events
Alerting software is used to notify impacted teams of potential security events.
Endpoint Security
Company endpoints are managed and configured with a strong password policy, anti-virus, and hard drive encryption
Network Traffic Monitoring
Security tools are implemented to provide monitoring of network traffic to the production environment.
Restricted Port Configurations
Configurations ensure available networking ports, protocols, services, and environments are restricted as necessary, including firewalls.

Access Security

Administrative Access is Restricted
Administrative access to production infrastructure is restricted based on the principle of least privilege.
Encryption-in-Transit
Service data transmitted over the internet is encrypted-in-transit.
Asset Inventory
A list of system assets, components, and respective owners are maintained and reviewed at least annually
Access to Product is Restricted
Non-console access to production infrastructure is restricted to users with a unique SSH key or access key
Complex Passwords
Personnel are required to use strong, complex passwords and a second form of authentication to access sensitive systems, networks, and information
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Encryption-at-Rest
Service data is encrypted-at-rest.
Encryption and Key Management Policy
An Encryption and Key Management Policy supports the secure encryption and decryption of app secrets, and governs the use of cryptographic controls.
Access Control and Termination Policy
An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.
Least Privilege in Use
Users are provisioned access to systems based on principle of least privilege.
Removal of Access
Upon termination or when internal personnel no longer require access, system access is removed, as applicable.

Physical Security

Physical Access Restrictions
Processes are in place to create, modify or remove physical access to facilities such as data centers, office spaces, and work areas based on the needs of such individual.
Physical Security Policy
A Physical Security Policy that details physical security requirements for the company facilities is in place.

Communications

Communication of Critical Information
Critical information is communicated to external parties, as applicable.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
Description of Services
Descriptions of the company's services and systems are available to both internal personnel and external users.
Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Confidential Reporting Channel
A confidential reporting channel is made available to internal personnel and external parties to report security and other identified concerns.
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.