Simonian Sports Medicine Clinic, A Medical Corporation

An ex-employee of a business associate (BA) impermissibly accessed the BA's website containing the electronic protected health information (ePHI) of 1,541 patients of the covered entity (CE). The ePHI affected by this incident included patients’ names, dates of birth, addresses, and other identifiers. The CE provided breach notification to HHS, and the BA provided breach notification to the affected individuals and the media. Following the breach, the CE changed its process for verifying patients’ insurance coverage, provided additional HIPAA training to its BAs, and documented the impermissible disclosure in the affected patients’ records for accounting of disclosure purposes. In addition, the CE revised BA agreements, policies and procedures, conducted a new annual risk analysis of its ePHI, and implemented encryption and tools to monitor internet traffic and compliance. OCR obtained assurances that the CE implemented the corrective actions listed.