Survey: To Report or Not Report Health Care Data Breaches

To Report or Not Report Health Care Data Breaches

December 11, 2020
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The American Journal of Managed CareDecember 2020, Volume 26, Issue 12

This study presents information regarding the decisions that health care privacy officers make about reporting a data breach, including factors that can affect the decision process, such as personal/organizational knowledge, prior breach status, and framed scenarios.


Objectives: The study’s objectives were to explore the impact of personal/organizational knowledge, prior breach status of organizations, and framed scenarios on the choices made by privacy officers regarding the decision to report a breach.

Study Design: A survey was completed of 123 privacy officers who are members of the American Health Information Management Association (AHIMA).

Methods: The study used primary data collection through a survey. Individuals listed as privacy officers within the AHIMA were the target audience for the survey. Descriptive statistics, logistic regression, and predicted probabilities were used to analyze the data collected.

Results: The percentage of privacy officers who chose to report a breach to the Office for Civil Rights varied by scenario: scenario 1 (general with little information), 39%; scenario 2 (4-factor risk assessment, paper records), 73.2%; scenario 3 (4-factor risk assessment, ransomware case), 91.9%. Several factors affected the response to each scenario. In scenario 1, privacy officers with a Certified in Healthcare Privacy and Security (CHPS) credential were less likely to report; those who previously reported a prior breach were more likely to report. In scenario 2, privacy officers with a bachelor’s degree or graduate education were less likely to report; those who held the CHPS or coding credential were less likely to report.

Conclusions: Study findings show there are gray areas where privacy officers make their own decisions, and there is a difference in the types of decisions they are making on a day-to-day basis. Future guidance and policies need to address these gaps and can use the insight provided by the results of this study.

Am J Manag Care. 2020;26(12):e395-e402.

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