ILLINOISAccidentalHealthcareHealthcareMisconfigurationBusiness Associate (HIPAA)Customer Data InvolvedDelayed DiscoveryPHIHealth (basic)MediumContained

HealthFitness

bd_033902d3818b9cd3 · schema v1 · pii pii-v1

Severity

Medium

Financial impact

$228K

Discovered

Jun 27, 2018

Filed

Jan 25, 2019

To disclose

30 weeks

Affected

1,808

Confidence

66%

Full breach record for HealthFitness →3 incidents on file

HealthFitness reported to HHS on 2019-01-25 a Unauthorized Access/Disclosure affecting 1808 individuals. Breached information located on Other. The incident involved a software misconfiguration on a server housing ePHI, discovered on June 27, 2018. Health Fitness, a business associate, failed to conduct a thorough risk analysis. A $227,816 settlement was reached with OCR.

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HIPAA clock✗ HHS report late30 weeks discovery → filing

⚠ unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Incident timeline

undetected · 1061 days

discovery → filing · 30 weeks / 212 days

Aug 1, 2015

Begins

Jun 27, 2018

Discovered

Jan 25, 2019

Filed

vs. sector median

+21 wks slower

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed1,808 affectedView incident

Name: HealthFitness
norm: healthfitness
Industry: Health Care Services

Name: HealthFitness
norm: healthfitness
Industry: Healthcaresource default

Discovered: Jun 27, 2018
Breach occurred: Aug 1, 2015
Undetected for: 1,061 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 1,808nationwide
Data types: PHIHealth (basic)
HHS breach type: Unauthorized access or disclosure
Where the data lived: Other
Covered-entity type: Business associate
Attack vector: Misconfiguration
MITRE ATT&CK: T1190 Exploit Public-Facing Application
Threat actor: External
Third party: via Health Fitness Corporationbusiness associate
Initial access: exploit_public_facing

During the incident: Paid $227,816 to OCR
Agreed to implement a corrective action plan that OCR will monitor for two years
Changes made: Annually reviewing and updating as necessary its risk analysis to determine the potential risks and vulnerabilities to the confidentiality, integrity, and availability of its ePHI
Developing and implementing a risk management plan to address and mitigate security risks and vulnerabilities identified in its risk analysis
Implementing a process for evaluating environmental and operational changes that affect the security of ePHI
Developing, maintaining, and revising, as necessary, certain written policies and procedures to comply with the HIPAA Privacy, Security, and Breach Notification Rules
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 30 weeks(212 days from discovery to filing)
Compliance flags: HHS report lateHHS notified
Discovery-date grounding: unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: Jun 27, 2018
→ Notified: not extracted
— 60 days HHS report late
HIPAA
Discovered: Jun 27, 2018
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jun 27, 2018 → Notified: not extracted	—	60 days	HHS report late
HIPAA	Discovered: Jun 27, 2018 → Notified: not extracted	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://ocrportal.hhs.gov/ocr/breach/breach_report.jsf
DisclosureLens renders the full SEC/HHS filing inline below from the originating regulator’s public record (§4.5 fair report privilege).
Filed at: Jan 25, 2019
Raw hash: 6d6be16ad7286f2ab541f630a82c9f253b80832d6e51e2220ee6cdb6186bb6ce

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Reporting entityHealthFitness

Victim entityHealthFitness

Incidentdiscovered Jun 27, 2018

Stated responsePaid $227,816 to OCR

ComplianceHHS report late

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing