Sisters of Charity of Leavenworth Health System Health Benefits Plan

A sub-subcontractor for the business associate (BA), Kaiser Permanente Insurance Company, incorrectly changed a setting on a printer press during maintenance, resulting in errors on printed, explanation of benefit (EOB), letters. The error impacted the letters of 540 individuals. The protected health information (PHI) involved in the breach included names, addresses, annual deductibles, annual out of pocket maximums, dollars spent “year-to-date” towards the deductible, and out-of-pocket maximums. The BA provided breach notification to HHS, affected individuals, and the media. Following the breach, the subcontractor BA responsible for printing the EOB’s updated its procedures to include additional oversight by its workforce members and additional print testing during printer updates or maintenance. OCR reviewed the applicable BA agreements, and its investigation resulted in the BA improving safeguards for the printing of PHI for the CE's health plan.