HIPAA Breach News

Class Action Lawsuit Seeks Damages for Victims of CVS Caremark Data Breach

An alleged healthcare data breach that saw the protected health information of patients of CVS Caremark exposed has resulted in legal action against CVS, Caremark, and its mailing vendor, Fiserv.

The lawsuit, which was filed in Ohio federal court on March 21, 2018, relates to an alleged privacy breach that occurred as a result of an error that affected a July/August 2017 mailing sent to approximately 6,000 patients.

In July 2017, CVS Caremark was contracted to operate as the pharmacy benefits manager for the Ohio HIV Drug Assistance Program (PhDAP), and under that program, CVS Caremark provides eligible patients with HIV medications and communicates with them about prescriptions.

In July/August 2017, CSV Caremark’s mailing vendor Fiserve sent letters to patients containing their membership cards and information about how they could obtain their HIV medications.

In the lawsuit the complaint alleges HIV-related information was clearly visible through the plastic windows of the envelopes, allowing the information to be viewed by postal service workers, family members, and roommates. It is alleged the mailing resulted in the disclosure of the recipient’s HIV status.

According to Ohio Department of Health policies, information related to HIV should only be sent in non-window envelopes. The mailing would have violated those policies and Health Information Portability and Accountability Act (HIPAA) Rules.

Such a HIPAA breach would need to be reported to the Department of Health and Human Services’ Office for Civil Rights within 60 days of discovery of the breach; however, the complainant alleges no breach report was submitted to OCR and notifications were not sent to affected individuals – A further breach of HIPAA Rules.

Plaintiffs are seeking punitive and compensatory damages and coverage of their legal costs.

There have been other breaches of HIV information in recent weeks, including a mailing error by a vendor of Aetna. In that case, HIV-related information was visible through the clear plastic windows of envelopes in a mailing to 12,000 individuals. Aetna settled a class action lawsuit filed on behalf of victims of the breach for $17,161,200 and is currently suing its mailing vendor to recover the costs. Aetna was also fined by the New York Attorney General over the breach and settled that case for $1.15 million.

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Theft of Unencrypted Laptop Sees Pathology Lab Patients’ PHI Exposed

An unencrypted laptop computer issued to an employee of Clinical Pathology Laboratories Southeast, Inc., (CPLSE) has been stolen, exposing the protected health information of certain patients and their payment guarantors.

Prompt action was taken by CPLSE to prevent the laptop from being used to connect to its network and the theft was reported to law enforcement; however, it is possible that the protected health information stored on the laptop could have been viewed by unauthorized individuals.

An internal investigation was conducted to determine the types of information stored on the device which indicated the following PHI elements were potentially exposed: Names, addresses, driver’s license numbers, Social Security numbers, government ID numbers, medical record numbers, and medical treatment information.

Patients have now been notified of the breach and advised of the steps they can take to protect themselves against misuse of their data. Complimentary credit monitoring and identity theft protection services have been offered to affected individuals.

Steps have also been taken to prevent similar incidents from occurring in the future, which include retraining staff on data security, updating appropriate policies and procedures, and using encryption technology on portable electronic devices used to store ePHI.

The laptop was stolen on September 20, 2017 and the substitute breach notice uploaded to the CPLSE website on March 21, 2018. It is unclear why it took 6 months for the incident to be announced. HIPAA requires notifications to be issued within 60 days of the discovery of a breach.

The incident has yet to appear on the Department of Health and Human Services’ Office for Civil Rights Breach Portal. The number of individuals affected has not yet been confirmed.

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ATI Physical Therapy Data Breach Impacts 35,000 Patients

ATI Physical Therapy has discovered the protected health information of more than 35,000 patients has potentially been accessed after threat actors gained access to the email accounts of some of its employees.

A security breach was identified on January 18, 2018 when ATI Physical Therapy discovered the direct deposit information of some of its employees had been changed in its payroll platform. Prompt action was taken to protect its employees and external forensic investigators were called in to determine the full extent and scope of the breach.

The investigation revealed the email accounts of certain employees had been compromised and were accessed by unauthorized individuals between January 9 and January 12, 2018. An analysis of the emails in the accounts revealed they contained the protected health information of tens of thousands of patients.

The types of information potentially compromised varied per impacted individual, but may have included names, dates of birth, credit/debit card numbers, driver’s license numbers, state ID numbers, Social Security numbers, Medicare/Medicaid information, health insurance information, billing/claims information, medical record numbers, patient ID numbers, financial account numbers, disability codes, diagnoses, treatment information, prescription information, and physicians’ and therapists’ names.

ATI Physical Therapy reports that only a small number of patients had their Social Security numbers exposed.

Patients impacted by the phishing incident have now been notified by mail and have been offered credit monitoring services without charge. Patients will also be protected by a $1 million identity theft insurance policy. No evidence of misuse of information has been uncovered by ATI Physical Therapy of the forensic investigators.

ATI Physical Therapy’s investigation into the breach is ongoing and steps have been taken to strengthen email security to prevent future breaches and employees have been provided with training to help them identify phishing emails.

The Department of Health and Human Services’ Office for Civil Rights breach report indicates 35,136 patients have potentially have their protected health information accessed.

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Insider Data Breaches Continue to Plague the Healthcare Industry

Protenus has published its February Healthcare Breach Barometer Report. The report includes healthcare data breaches reported to the Department of Health and Human Services’ Office for Civil Rights or disclosed to the media in February 2018.

The report, compiled from data collected from databreaches.net, indicates at least 348,889 healthcare records were confirmed as breached in February, although that figure will be considerably higher as the number of people affected by 11 breaches is not yet known. There were 39 security breaches involving protected health information in February – a slight rise from the 37 breaches reported in January, although the number of records exposed was down from January’s total of 473,807 records.

Insider breaches continue to pose problems for healthcare providers with 16/39 incidents (41%) involving insiders. Those incidents resulted in the exposure/theft of 51% of all records confirmed as having been exposed or stolen in February. Protenus notes that 94% of insider breaches were the result of errors by healthcare employees, with only one confirmed breach involving insider wrongdoing.

Hacking accounted for 33% of data breaches and resulted in the exposure of 46% of the records exposed in February, although the number of people affected by five hacking incidents is not yet known. Out of the hacking/IT incidents, four were confirmed as involving malware or ransomware, including the largest breach of the month – the 135,000-record breach at St. Peter’s Surgery & Endoscopy Center in New York. There were two incidents confirmed as involving phishing. Theft/loss incidents accounted for 13% of all breaches and the cause of 13% of breaches is currently unknown.

Healthcare providers reported 23 breaches, health plans reported eight incidents, business associates reported four incidents, and businesses/other vendors reported four breaches. The breach reports submitted to the Office for Civil Rights only suggest two business associate breaches occurred, although the Protenus report has revealed there were 11 incidents with some business associate/vendor involvement.

Protenus notes that it took an average of 325 days from the date of the breach to the incident being discovered with a median detection time of 34 days. The average was high due to one insider breach taking more than four years to discover. The average time from discovery to reporting was 68 days with a median of 59 days. Six organizations reported the breaches later than the 60-day maximum time frame allowed by HIPAA.

California was the worst affected by healthcare data breaches in February with six incidents followed by Wisconsin and Georgia on three. Healthcare data breaches were reported by organizations in 22 states and Puerto Rico in February.

Protenus notes that while the number of people affected by healthcare data breaches fell to a four year low in 2017, the number of data breaches has not reduced. Healthcare data breaches are still occurring at a rate of more than one per day.

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Ransomware Attack on Finger Lakes Health Cripples Computers

Geneva, NY-based Finger Lakes Health has experienced a ransomware attack that has crippled its computer system. Staff have been forced to work on pen and paper while the health system attempts to remove the malware and restore access to electronic data.

The ransomware attack on the health system started at around midnight on Sunday March 18, 2018, with staff becoming aware of the attack when a ransom demand was issued by the attackers.

Finger Lakes Health operates Geneva General Hospital and Soldiers & Sailors Memorial Hospital in Pen Yan and several specialty care practices, primary care physician practices, long-term health facilities, and day care centers in upstate New York. It is unclear exactly how many facilities have been impacted by the ransomware attack.

Finger Lakes Health has developed emergency procedures for attack scenarios such as this, which were immediately implemented when the attack was discovered. On March 20, the health system issued a statement to local media channels about the attack explaining that while some of its information systems were inaccessible, its manual downtime protocol had been implemented and its hospitals and care facilities continued to function. Such an attack will naturally have an impact on the provision of medical services, although patient care remains the main priority while the ransomware attack is mitigated.

Finger Lakes Health is working closely with law enforcement and IT teams to restore access to data and bring its systems back online. At this stage it appears that the attackers have only encrypted data. There is no indication that any patient or employee information has been compromised.

No information on the type of ransomware used in the attack has been released nor whether the decision has been made to pay the ransom to regain access to data.

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RoxSan Pharmacy Notifies 1,049 Patients About 2015 Email Breach

Beverly Hills, CA-based RoxSan Pharmacy has notified 1,049 patients that some of their protected health information has been disclosed to a business associate via unencrypted email.

The notification letters were mailed to affected individuals last month, although the incident occurred on January 20, 2015. In a recent press release, RoxSan explained that affected individuals are being notified in “as timely a manner as possible”. The delay in issuing notifications was due to “the protected nature of the forensic investigation”. It is unclear when RoxSan Pharmacy became aware of the error.

The protected health information was included in a data file that was sent to a single individual – A business associate of the pharmacy – who worked in the legal field. That individual had signed a business associate agreement with the pharmacy and was aware of the responsibilities of HIPAA with respect to patients’ PHI. However, the PHI was exposed as the data file was sent via unencrypted email.

The data file only contained a limited amount of protected health information and did not include patient names, personal identification information, Social Security numbers, or financial information.

The information related to patients who had prescriptions filled between April 2015 and August 2015 and was limited to prescription information, drug information, insurance information, physicians’ names, and patient identification numbers.

RoxSan has not received any reports that suggest the information has been intercepted and misused. Patients have been advised of the steps they can take to protect their identities and monitor for fraudulent use of their information as a precaution.

The pharmacy has already taken steps to improve its operational protections to prevent any further breaches of this nature from occurring.

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Healthcare Data Breach Statistics

We have compiled healthcare data breach statistics from October 2009 when the Department of Health and Human Services’ Office for Civil Rights first started publishing summaries of healthcare data breaches on its website.

The healthcare data breach statistics below only include data breaches of 500 or more records as smaller breaches are not published by OCR. The breaches include closed cases and breaches still being investigated by OCR.

Our healthcare data breach statistics clearly show there has been an upward trend in data breaches over the past 9 years, with 2017 seeing more data breaches reported than any other year since records first started being published.

There have also been notable changes over the years in the main causes of breaches. The loss/theft of healthcare records and electronic protected health information dominated the breach reports between 2009 and 2015, although better policies and procedures and the use of encryption has helped reduce these easily preventable breaches. Our healthcare data breach statistics show the main causes of healthcare data breaches is now hacking/IT incidents, with unauthorized access/disclosures also commonplace.

Healthcare Data Breaches by Year

Between 2009 and 2017 there have been 2,181 healthcare data breaches involving more than 500 records. Those breaches have resulted in the theft/exposure of 176,709,305 healthcare records.  That equates to more than 50% of the population of the United States (54.25%). Healthcare data breaches are now being reported at a rate of more than one per day.

Healthcare data breaches 2019-2017

Healthcare Records Exposed by Year

While there has been a general upward trend in the number of records exposed each year, there was a massive improvement in 2017 – the best year since 2012 in terms of the number of records exposed. However, while breaches were smaller in 2017, it was a record breaking year in terms of the number of healthcare data breaches reported – 359 incidents.

Records Exposed in Healthcare data breaches

Average/Median Healthcare Data Breach Size by Year

Average Size of Healthcare Data Breaches

 

Median Size of Healthcare Data Breaches

 

Largest Healthcare Data Breaches (2009-2017)

Rank Year Entity Entity Type Records Exposed/Stolen Cause of Breach
1 2015 Anthem, Inc. Affiliated Covered Entity Health Plan 78800000 Hacking/IT Incident
2 2015 Premera Blue Cross Health Plan 11000000 Hacking/IT Incident
3 2015 Excellus Health Plan, Inc. Health Plan 10000000 Hacking/IT Incident
4 2011 Science Applications International Corporation Business Associate 4900000 Loss
5 2014 Community Health Systems Professional Services Corporation Business Associate 4500000 Theft
6 2015 University of California, Los Angeles Health Healthcare Provider 4500000 Hacking/IT Incident
7 2013 Advocate Medical Group Healthcare Provider 4029530 Theft
8 2015 Medical Informatics Engineering Business Associate 3900000 Hacking/IT Incident
9 2016 Banner Health Healthcare Provider 3620000 Hacking/IT Incident
10 2016 Newkirk Products, Inc. Business Associate 3466120 Hacking/IT Incident
11 2016 21st Century Oncology Healthcare Provider 2213597 Hacking/IT Incident
12 2014 Xerox State Healthcare, LLC Business Associate 2000000 Unauthorized Access/Disclosure
13 2011 IBM Business Associate 1900000 Unknown
14 2011 GRM Information Management Services Business Associate 1700000 Theft
15 2010 AvMed, Inc. Health Plan 1220000 Theft
16 2015 CareFirst BlueCross BlueShield Health Plan 1100000 Hacking/IT Incident
17 2014 Montana Department of Public Health & Human Services Health Plan 1062509 Hacking/IT Incident
18 2011 The Nemours Foundation Healthcare Provider 1055489 Loss
19 2010 BlueCross BlueShield of Tennessee, Inc. Health Plan 1023209 Theft
20 2011 Sutter Medical Foundation Healthcare Provider 943434 Theft

Healthcare Hacking Incidents by Year

Our healthcare data breach statistics show hacking is now the leading cause of healthcare data breaches, although healthcare organizations are now much better at detecting breaches when they do occur. The low hacking/IT incidents in the earlier years is likely to be due, in part, to the failure to detected hacking incidents and malware infections quickly. Many of the hacking incidents in 2014-2017 occurred many months, and in come cases years, before they were detected.

Healthcare Data Breaches - Hacking

 

Records Exposed in Healthcare Data Breaches - Hacking

Unauthorized Access/Disclosures by Year

As with hacking, healthcare organizations are getting better at detecting internal breaches and also reporting those breaches to the Office for Civil Rights. While hacking is the main cause of breaches, unauthorized access/disclosure incidents are in close second.

Healthcare Data Breaches - unauthorized access/disclosures

 

records exposed in authorized access/disclosures

Loss/Theft of PHI and Unencrypted ePHI by Year

Our healthcare data breach statistics show HIPAA covered entities and business associates have got significantly better at protecting healthcare records with administrative, physical, and technical controls such as encryption, although unencrypted laptops and other electronic devices are still being left unsecured in vehicles and locations accessible by the public.

healthcare theft/loss data breaches

 

records exposed by healthcare theft/loss data breaches

Improper Disposal of PHI/ePHI by Year

healthcare data breaches - improper disposal incidents

 

records exposed in healthcare improper disposal incidents

 

Breaches by Entity Type

Year Provider Health Plan Business Associate Other Total
2009 14 1 3 0 18
2010 134 21 44 0 199
2011 137 20 42 1 200
2012 155 22 36 4 217
2013 199 18 56 5 278
2014 202 71 41 0 314
2015 196 62 11 0 269
2016 257 51 19 0 327
2017 288 52 19 0 359
Total 1582 318 271 10 2181

OCR Settlements and Fines for HIPAA Violations

The penalties for HIPAA violations can be severe with multi-million-dollar fines possible when violations have been allowed to persist for several years or when multiple violations of HIPAA Rules have been allowed to occur.

The penalty structure for HIPAA violations is detailed in the infographic below:

Penalty Structure for HIPAA Violations

OCR Settlements and Fines Over the Years

The data for the healthcare data breach statistics on fines and settlements can be viewed on our HIPAA violation fines page, which details all HIPAA violation fines issued by OCR between 2008 and 2018. As the graph below shows, there has been a steady increase in HIPAA enforcement over the past 9 years.

HIPAA Fines and Settlements 2008-2017

 

How Much Has OCR Fined HIPAA Covered Entities and Business Associates?

In addition to an increase in fines and settlements, the level of fines has increased substantially. Multi-million-dollar fines for HIPAA violations are now the norm.

HIPAA Fine and Settlement Amounts 2008-2017

 

average HIPAA Fines and Settlements 2008-2017

 

Median HIPAA Fines and Settlements 2008-2017

As the graphs above show, there has been a sizable increase in both the number of settlements and civil monetary penalties and the fine amounts in recent years. OCR’s budget has been cut so there are fewer resources to put into pursuing financial penalties in HIPAA violation cases. 2018 is likely to see fewer fines for HIPAA covered entities than the past two years, although settlement amounts are likely to remain high and even increase in 2018.OCR Director Roger Severino has indicated financial penalties are most likely to be pursued for particularly egregious HIPAA violations.

State Attorneys General HIPAA Fines and Other Financial Penalties for Healthcare Organizations

State attorneys general can issue fines ranging from $100 per HIPAA violation up to a maximum of $25,000 per violation category, per year.

Even when action is taken by state attorneys general over potential HIPAA violations, healthcare organizations are typically fined for violations of state laws. Only a handful of U.S. states have issued fines solely for HIPAA violations

Some of the major fines issued by state attorneys general for HIPAA violations and violations of state laws are listed below.

 

Year State Covered Entity Amount Individuals affected Settlement/CMP Reason
2018 NY EmblemHealth $575,000 81,122 Settlement Mailing error
2018 NY Aetna $1,150,000 12,000 Settlement Mailing error
2017 CA Cottage Health System $2,000,000 More than 54,000 Settlement Failure to adequately protect medical records
2017 MA Multi-State Billing Services $100,000 2,600 Settlement Theft of unencrypted laptop containing PHI
2017 NJ Horizon Healthcare Services Inc., $1,100,000 3.7 million Settlement Loss of unencrypted laptop computers
2017 VT SAManage USA, Inc. $264,000 660 Settlement Spreadsheet indexed by search engines and PHI viewable
2017 NY CoPilot Provider Support Services, Inc $130,000 221,178 Settlement Delayed breach notification
2015 NY University of Rochester Medical Center $15,000 3,403 Settlement List of patients provided to nurse who took it to a new employer
2015 CT Hartford Hospital/ EMC Corporation $90,000 8,883 Settlement Theft of unencrypted laptop containing PHI
2014 MA Women & Infants Hospital of Rhode Island $150,000 12,000 Settlement Loss of backup tapes containing PHI
2014 MA Boston Children’s Hospital $40,000 2,159 Settlement Loss of laptop containing PHI
2014 MA Beth Israel Deaconess Medical Center $100,000 3,796 Settlement Loss of laptop containing PHI
2013 MA Goldthwait Associates $140,000 67,000 Settlement Improper disposal
2012 MN Accretive Health $2,500,000 24,000 Settlement Mishandling of PHI
2012 MA South Shore Hospital $750,000 800,000 Settlement Loss of backup tapes containing PHI
2011 VT Health Net Inc. $55,000 1,500,000 Settlement Loss of unencrypted hard drive/delayed breach notifications
2011 IN WellPoint Inc. $100,000 32,000 Settlement Failure to report breach in a reasonable timeframe
2010 CT Health Net Inc. $250,000 1,500,000 Settlement Loss of unencrypted hard drive/delayed breach notifications

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Analysis of February 2018 Healthcare Data Breaches

Our February 2018 healthcare data breach report details the major data breaches reported by healthcare providers, health plans, and business associates in February 2018.

Summary of February 2018 Healthcare Data Breaches

February may have been a shorter month, but there was an increase in the number of healthcare data breaches reported to the Department of Health and Human Services’ Office for Civil Rights. In February, HIPAA covered entities and business associates reported 25 breaches – a 19% month on month increase in breaches.

Healthcare Data Breaches by Month

While there was a higher breach tally this month, the number of healthcare records exposed as a result of healthcare data breaches fell by more than 100,000. In January 428,643 healthcare records were exposed. February 2018 healthcare data breaches saw 308,780 healthcare records exposed.

Records exposed in Healthcare Data Breaches

Largest Healthcare Data Breaches of February 2018

The largest healthcare data breaches reported to the Office for Civil Rights in February are listed below.

Covered Entity Covered Entity Type Individuals Affected Type of Breach Location of PHI
St. Peter’s Surgery & Endoscopy Center Healthcare Provider 134,512 Hacking/IT Incident Network Server
Tufts Associated Health Maintenance Organization, Inc. Health Plan 70,320 Unauthorized Access/Disclosure Paper/Films
Triple-S Advantage, Inc. Health Plan 36,305 Unauthorized Access/Disclosure Paper/Films
CarePlus Health Plan Health Plan 11,248 Unauthorized Access/Disclosure Paper/Films
Union Lake Supermarket, LLC Healthcare Provider 9,956 Improper Disposal Other Portable Electronic Device

The top five data breaches were responsible for 85% of all exposed healthcare records in February. The largest data breach – a malware-related incident at St. Peter’s Surgery & Endoscopy Center – accounted for 43.6% of the exposed healthcare records in February.

Main Causes of February 2018 Healthcare Data Breaches

Unauthorized access/disclosures topped the list of the main causes of healthcare data breaches in February 2018 with 12 incidents and included three of the most serious breaches. Hacking incidents were in close second with 9 breaches, followed by three loss/theft incidents and one case of improper disposal of ePHI.

Causes of February 2018 Healthcare Data Breaches

Records Exposed by Breach Type

Hacking/IT incidents were the second biggest cause of healthcare data breaches in February, but the incidents resulted in the exposure/theft of the largest amount of healthcare data.

Records Exposed by Breach Type

Location of Breached Records

Overall, there were more breaches involving electronic health data than physical records, although breaches involving paper/films were the most numerous with 6 incidents. The breach reports show that while technological controls are essential to prevent hacks and unauthorized access/disclosures of electronic records, physical security is important for paper records and administrative safeguards are necessary to prevent unauthorized access. All six of the breaches involving paper/films were unauthorized access/disclosures.

Location of breached healthcare records (February 2018)

Data Breaches by Covered Entity

Healthcare providers were the worst affected by data breaches in February with 15 incidents (reported by 14 healthcare providers). There were three breaches reported by pharmacies in February. 8 data breaches were reported by 7 health plans and two security incidents were reported by business associates.

Data Breaches by Covered Entity (February 2018)

Healthcare provider breaches exposed the most health records in February. 168,732 records were exposed by healthcare providers. The mean breach size was 11,248 records and the median breach size was 1,670 records.

Health plans experienced fewer breaches, but the incidents were more severe. 133,580 records were exposed by health plans. The mean breach size was 16,698 records and the median breach size was 6,075 records. The mean and median breach size for business associate data breaches was 3,234 records.

Records exposed by covered entity (February 2018)

February 2018 Healthcare Data Breaches by State

Healthcare organizations based in 18 states reported data breaches in February 2018. There were six states that experienced 2 data breaches– Alabama, California, Massachusetts, Mississippi, Rhode Island, and Wisconsin.

Arkansas, Connecticut, Illinois, Kentucky, Maine, Michigan, Missouri, North Carolina, New Jersey, New York, Tennessee, and Virginia each had one data breach reported.

Financial Penalties for HIPAA Covered Entities in February 2018

The Office for Civil Rights settled one HIPAA violation case in February. Filefax Inc, agreed to settle potential HIPAA violations with OCR for $100,000. The financial penalty sent a message to HIPAA-covered entities and their business associates that HIPAA responsibilities do not end when a business ceases trading. The fine relates to HIPAA violations that occurred after the business closed – the improper disposal of paperwork containing protected health information.

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Multiple Email Accounts Compromised at Primary Health Care

Primary Health Care Inc., a non-profit network of community health centers in Des Moines, Marshalltown and Ames, IA, has discovered malicious actors have gained access to the email accounts of four employees and have potentially viewed or obtained patients’ protected health information.

Primary Health Care issued a press release and uploaded a substitute breach notice to its website on March 16, 2018 explaining the breach occurred on February 28, 2017. The breach was detected the following day on March 1, 2017. Primary Health Care is in the process of notifying affected patients and will be reporting the incident to the Department of Health and Human Services’ Office for Civil Rights. No explanation is provided as to why the breach took a year to report, although the timing of the breach notice suggests the year stated in the breach notice may be a typo and that the breach occurred this year.

Primary Health Care responded quickly to the breach and terminated access to the compromised email accounts and hired a third-party computer forensics expert to conduct an investigation into the attack. The investigation revealed access to four email accounts and their associated Google Drives was gained by the attacker(s), although it was not possible to tell whether any emails were opened and if any protected health information was viewed.

An analysis of the email accounts revealed they contained information such as patients’ names along with driver’s license numbers, Social Security numbers, diagnoses, treatment information, medical histories, health insurance/payor information, facilities and providers visited, financial account numbers, credit/debit card numbers, dates of service, and in some cases, Medicaid numbers.

No evidence has been found to suggest any information has been misused, although out of an abundance of caution, affected individuals have been offered 12 months of identity theft protection services through AllClear without charge.

Primary Health Care is in the process of implementing additional security measures to enhance the privacy and security of its information systems to prevent further breaches of this nature.

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