When I emailed Overlake OB/GYN in July about a ransomware attack in 2020, I didn’t anticipate what would happen next.

In December, 2019, Overlake Medical Center & Clinics discovered that some employees had fallen for a phishing scheme. On February 7, 2020, they reported the incident to HHS as impacting 109,234 patients. As HHS subsequently summarized things:

After the breach, the [Covered Entity] implemented additional administrative and technical safeguards and retrained its staff on the proper methods of identifying and responding to fraudulent email communications.

Whatever they did after the 2019 attack may not have been sufficient, because nine months later, the Overlake OB/GYN clinic appears to have fallen victim to a ransomware attack.

That attack was revealed in July, 2021, by Pysa threat actors, who claimed that they attacked the clinic on November 29, 2020.

Overlake Listing

But did Overlake OB/GYN ever disclose that 2020 breach on their site or in a press release? If so, DataBreaches.net never saw it, and the clinic remained silent, ignoring  this site’s inquiries, even after Pysa dumped more than 8,900 files and more than 3.8 GB of data.

DataBreaches.net reported on the attack and data dump on August 3, 2021, noting the clinic’s lack of response to emails sent to it on July 27 and July 29.

Fast forward to this past week.  What appeared to be a November, 2020 ransomware incident still has not appeared on HHS’s public breach tool.  Nor has this site found any disclosure of that breach to regulators or patients. Both of those are concerning enough, but…

Has there been a third breach?

Has there been a third breach, or did Overlake just fail to successfully remediate the 2020 ransomware attack in a timely fashion (if at all)?

On November 10, DataBreaches.net received four emails from four different forged addresses that had nothing to do with Overlake OB/GYN.

The emails all had the same subject line that indicated a response to this site’s July 27, 2021 email to Overlake.  The bodies of all four emails included the full text and signature block of the July 27, 2021 email to the clinic.

And all four emails also contained an attached trojan downloader: Win32/Powdow!ml

So how did an email sent to Overlake on July 27, 2021 —  8 months after the alleged ransomware attack by Pysa — wind up in the hands of criminals? When did it get exfiltrated from Overlake’s system —  back in July or even later?

Had Overlake had yet another breach or had they just been unable to really contain a malware incident of 2020?

And if this site’s email to Overlake OB/GYN  was exfiltrated on or after July 27, 2021, how much patient data, if any, was also exfiltrated at that point or after that date that was never dumped on Pysa’s dark web site?  Was it even Pysa who was receiving data by July of 2021?  And if so, who were they sharing it with?

DataBreaches.net sent Overlake OB/GYN another email this past week — this one concerning the exfiltration of email to them from their system on or after July 27, 2021.  They did not respond to that email, either, or to an attempt to contact them on Twitter.

So it looks like this week, DataBreaches.net will file a watchdog complaint with HHS asking HHS to investigate the alleged November, 2020 ransomware incident and whether Overlake ever properly notified regulators and patients;  why data was (still?) apparently being exfiltrated on or after July 27, 2021, whether Overlake ever properly remediated any November, 2020 ransomware incident, and whether Overlake OB/GYN has complied with HIPAA’s Security Rule and HITECH.

Maybe HHS can get some answers. If Overlake OB/GYN does reply to this site’s inquiry, this post will be updated.

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