Short answer: probably, and the consumer travel site you use today will not sign one. Here is the plain-language reasoning for the person who has to defend it to compliance.
When a member travels for a covered procedure, member information leaves your four walls: a name, dates, and a destination that points at a specific treating facility, sometimes a companion and a reason for travel. Tied to a member and a facility, that is exactly the kind of information HIPAA exists to protect.
The rule of thumb: if an outside vendor creates, receives, maintains, or transmits protected health information to perform a service for you, that vendor is generally a business associate, and a Business Associate Agreement governs how they handle it. A travel vendor booking trips for your plan members fits that description.
Consumer travel sites are not built for this. They are not your business associate, they will not sign a BAA, and their terms assume a consumer booking their own trip. The common pattern, a coordinator on a consumer site with the corporate card, quietly sends member information to a vendor who signed nothing, and it usually surfaces during an audit.
No. They are explicitly not business associates and their terms of service assume a consumer booking their own trip, which is why hand-booking member travel on a consumer site is a quiet compliance gap.
Yes, before a single member record moves. Carepassage collects only the minimum member data needed to book, encrypts it at rest, audits every read and write, and publishes its subprocessor list.
No. It is operational guidance. Your privacy officer or counsel makes the final call on what your plan requires.