Dr. Douglas C. Morrow, OD Notifies Patients of Data Security Incident
Look at the timeline. Was this a ransomware incident that encrypted data and made it more difficult to investigate? Why did it take so long from some of these benchmarks to notification?
AUBURN, Ind., Feb. 23, 2022 /PRNewswire/ — On May 16, 2021, Dr. Douglas C. Morrow, OD (“Dr. Morrow”) experienced a data security incident that prevented users from accessing systems and data. Upon discovering this incident, Dr. Morrow immediately launched an investigation and engaged a digital forensics firm to help determine what happened and what information may have been accessed. On October 29, 2021, the investigation determined that the attacker gained access to Dr. Morrow’s data and may have acquired protected health information.
Why did it take more than 5 months from the incident with an investigation that was immediately launched to figure out that there had been access to data and possible acquisition of protected health information?
On December 8, 2021, Dr. Morrow identified individuals whose protected personal information may have been compromised. The types of information potentially accessed varied by individual, but may have included name, address, Social Security number, driver’s license, medical information, and health insurance information. The specific types of medical information and/or health insurance information that may have been accessed include Member/Medicaid ID numbers, treatment/diagnosis information, dates of service, provider name(s), patient account number(s), and medical record number(s).
Impacted individuals were notified beginning on February 23, 2022.
If individuals were identified on December 8, why did it take until February 23 to send letters? And how many patients were notified?
Seriously… the “no later than 60 calendar days” notification requirement has to have teeth or it should be revoked or amended. In this case, based on the timeline provided by the provider, what do you use as the date of discovery for determining when notification had to be made by (under HIPAA/HITECH)?
Read more at PRNewswire.