Capital Digestive Care, Inc.

The covered entity (CE), Capital Digestive Care, reported that on February 23, 2018, its business associate (BA), Laughlin, Marinaccio & Owens, Inc., stored data files on a commercial cloud server without adequate security. The information at issue was limited to the “Schedule a Visit” and “Contact” pages, which may have contained the protected health information (PHI) of approximately 17,639 individuals. The CE provided breach notification to HHS, affected individuals, and the media. OCR reviewed the CE’s risk assessment, policies and procedures on uses and disclosures of PHI and safeguards, as well as the security measures implemented to address risks and vulnerabilities. The CE provided a copy of the relevant BA agreement. OCR obtained assurances that the CE implemented the corrective actions listed.