Why doesn't Freshpaint need a BAA before sending data to Google Ads and Facebook Ads?

In general, a BAA is needed when sending PHI to a third party. PHI is defined as including both an identifier and health information, together. Freshpaint provides a way for its customers to send only identifiers or only health information to a third party. Since measuring ad campaign outcomes via Google and Facebook only requires identifiers and not health information, Freshpaint strips out all health information and sends only identifiers, therefore maintaining compliance without requiring a BAA.