Puerto Rico Department of Heatlh - Medicaid Program

The covered entity (CE) reported that on February 26, 2015, it became aware that a staff member within its Medicaid department was arrested for selling confidential and sensitive information from the Medicaid information system known as MEDITI. The staff member used his personal cell phone to capture pictures of specific screens within the MEDITI system that contained the electronic protected health information (ePHI) of 4,192 beneficiaries. The ePHI included individuals’ names, dates of birth, social security numbers, home addresses, phone numbers, gender, and income level. Following the breach, the CE conducted risk analyses and implemented risk management plans for the following entities: Hospital Universitario Dr. Ramon Ruiz Arnau, Administración de Servicios Médicos de Puerto Rico, University Pediatric Hospital, and Oficina Central para Asuntos del SIDA y Enfermedades Transmisibles, and the Ryan White program. In addition, the CE reviewed its HIPAA Privacy and Security Rule policies and procedures and in 2017 and 2018, retrained its staff. The CE also provided breach notification to HHS, affected individuals, and the media, and provided one year of credit protection. OCR obtained assurances that the CE implemented the corrective actions listed. The CE is expected to conduct a risk analysis and implement a corresponding remediation plan for its Medicaid Department; Emergency Department in Loiza; Women, Infants, and Children “WIC” Department; Intellectual Disability Department; Immunization Department; Demographic Registry Department; and the Local Centers for Diagnosis and Treatment located in Vieques and Adjuntas.