Med Assets

An unencrypted hard drive containing the electronic protected health information (ePHI) of 8,795 individuals was stolen from an employee of the covered entity's (CE) business associate (BA), MedAssets. The ePHI included names, dates of birth, social security number, account numbers, medical record numbers, charges incurred, amounts paid, admission and discharge dates, and information regarding health insurance and eligibility for applicable governmental benefit programs. Upon discovery of the breach, the CE, Clara Maass Medical Center, filed a police report, provided breach notification to HHS, the media, and affected individuals, and posted substitute notification on its website. As a result of OCR's investigation, the BA retrained the employee, instructed all employees to stop using any type of external storage device that contains ePHI, and recalled and destroyed all unencrypted external hard drives that contained ePHI. In addition, the BA improved technical safeguards by encrypting external hard drives and installing a new software system that monitors, controls and encrypts data leaving the BA's computers. The BA also hired an IT security analyst to supplement its security program. The breach incident involved a BA and occurred prior to the September 23, 2013, compliance date. OCR verified that the CE had a proper BA agreement in place that restricted the BA's use and disclosure of PHI and required the BA to safeguard all PHI. \ \