Colorado Community Health Alliance (CCHA)/Physicians Health Partners

On January 2, 2014, the covered entity (CE), Colorado Department of Health Care Policy and Financing, reported a breach by its business associate (BA), Colorado Community Health Alliance. On November 21, 2013, a temporary employee working for the BA’s subcontractor, Aerotek, sent a list via unencrypted email containing the electronic protected health information (ePHI) of 1,918 individuals to her personal email account. The ePHI included patients’ names, addresses, dates of birth, Medicaid identification numbers, and health conditions. The BA detected the email through its auditing program. The CE provided breach notification to HHS and the BA provided breach notification to affected individuals and the media and posted substitute notice. After the incident, the BA developed and implemented a policy requiring that emails containing ePHI be encrypted to prevent a similar incident from occurring in the future, and trained its workforce members accordingly. OCR provided substantial technical assistance to the BA, which implemented additional procedures and technical safeguards and provided written assurance that it will complete an enterprise-wide risk analysis.