NEW YORKMalwareHealthcareHealthcareRansomwareData EncryptedCustomer Data InvolvedPHIHealth (basic)Identity (basic)MediumContained

Comprehensive Neurology Specialists

bd_097711b88f56423c · schema v1 · pii pii-v1

Severity

Medium

Financial impact

$25K

Discovered

Dec 1, 2020

Filed

Dec 17, 2020

To disclose

16 days

Affected

6,800

Linked

2 filings

Confidence

69%

Full breach record for Comprehensive Neurology Specialists →

Comprehensive Neurology, PC reported to HHS on 2020-12-17 a Hacking/IT Incident affecting 6800 individuals. Breached information located on Electronic Medical Record, Network Server. The incident involved a ransomware attack that encrypted ePHI, including demographic and clinical information. A $25,000 settlement was reached with OCR.

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HIPAA clockDiscovered Dec 1, 2020 → Notified Dec 17, 202016d ✓ HHS report on time16 days 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

discovery → filing · 16 days

Dec 1, 2020

Discovered

Dec 17, 2020

Filed

vs. sector median

10 wks faster

This filing is one of 2 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (1) · sorted by filing gap

HHS OCR enforcementbd_5eeaba582402b4352025-04-25 · +1590dVerified by operator

Name: Comprehensive Neurology Specialists
norm: comprehensive neurology specialists
Domain: cnsneurologyspecialists.com
Industry: Health Care Services

Name: Comprehensive Neurology Specialists
norm: comprehensive neurology specialists
Domain: cnsneurologyspecialists.com
Industry: Healthcaresource default

Discovered: Dec 1, 2020
Materiality determined: —
Notification sent: Dec 17, 2020
Affected individuals: 6,800nationwide
Data types: PHIHealth (basic)Identity (basic)
HHS breach type: Hacking / IT incident
Where the data lived: Electronic medical recordNetwork server
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1486 Data Encrypted for Impact
Threat actor: ExternalFinancial
Regulator citations: Settlement resolves OCR investigation of a ransomware attackPaid $25,000 to OCR

During the incident: Agreed to implement a corrective action plan that will be monitored by OCR for two years
Paid $25,000 to OCR
Changes made: Conducting an accurate and thorough risk analysis to determine the potential risks and vulnerabilities to the ePHI in its information systems
Developing and implementing a risk management plan to address and mitigate reduce security risks and vulnerabilities identified in the risk analysis
Reviewing, and to the extent necessary, revising its written policies and procedures to comply with the HIPAA Rules
Training its workforce on its HIPAA policies and procedures
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 16 days(16 days from discovery to filing)
Compliance flags: HHS report on time · 16dHHS 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: Dec 1, 2020
→ Notified: Dec 17, 2020
16d 60 days HHS report on time
HIPAA
Discovered: Dec 1, 2020
→ Notified: Dec 17, 2020
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Dec 1, 2020 → Notified: Dec 17, 2020	16d	60 days	HHS report on time
HIPAA	Discovered: Dec 1, 2020 → Notified: Dec 17, 2020	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 2 filings

View merged incident ↗

HHS OCRDec 17 · first · this page

HHS OCR enforcement+1590d

Pattern: first filing Dec 17 (NY), last Apr 25 — a 1590-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

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: Dec 17, 2020
Raw hash: 95f321c9f8ed1c8c780052ca276a0f2b953a5dcce6de845b6d41929cef761afb

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Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityComprehensive Neurology Specialists

Victim entityComprehensive Neurology Specialists

Incidentdiscovered Dec 1, 2020

Stated responseAgreed to implement a corrective action plan that will be monitored by OCR for two years

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing