MASSACHUSETTSPhysicalHealthcareHealthcareLossBusiness Associate (HIPAA)Customer Data InvolvedPHIHealth (basic)Identity (basic)MediumContained

Center for Comprehensive Services, Inc.

bd_0d26ff4bf8f898ec · schema v1 · pii pii-v1

Severity

Medium

Discovered

—

Filed

Mar 21, 2018

To disclose

—

Affected

1,176

Confidence

69%

Full breach record for Center for Comprehensive Services, Inc. →

Center for Comprehensive Services, Inc. reported to HHS on 2018-03-21 a Loss affecting 1176 individuals. Breached information located on Other Portable Electronic Device. A business associate (Bullpen Financial, Inc.) mailed an unencrypted USB drive containing ePHI (demographic and some clinical info) which was lost in the mail. The CE engaged a forensics firm and notified individuals.

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HIPAA clock✓ HHS notified

⚠ no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.

⚠ No discovery dateThe OCR public portal omits the discovery date, so the 60-day notification clock cannot be evaluated from this source — only that the filing was submitted.

Incident timeline — partial

? — ?

Breach window unknown

Mar 21, 2018

Filed

—

No filing yet · watching

Compliance clocks stay unassessable until a regulatory filing lands. Dashed segments fill in automatically when corroboration arrives.

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed1,176 affectedView incident

Name: Center for Comprehensive Services, Inc.
norm: center for comprehensive
Industry: Health Care Services

Name: Center for Comprehensive Services, Inc.
norm: center for comprehensive
Industry: Healthcaresource default

Discovered: Not extracted — the OCR public portal omits it
Materiality determined: —
Notification sent: —
Affected individuals: 1,176nationwide
Data types: PHIHealth (basic)Identity (basic)
HHS breach type: Loss
Where the data lived: Portable electronic device
Covered-entity type: Healthcare providerBusiness associate involved
Attack vector: Unauthorized Access
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: Internal
Regulator citations: OCR provided technical assistance to the CE regarding the timeliness requirements of the breach notification rule, the definition of PHI, and the BA agreement requirements under the Rules.
Third party: via Bullpen Financial, Inc.business associate

During the incident: Engaged an outside forensics firm to investigate
Provided breach notification to affected individuals
Changes made: Entered into a BA agreement with its parent company
Source: Quoted from the filing itself, not independently verified.

Compliance flags: HHS notified
Discovery-date grounding: no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: not extracted
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: not extracted → 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: Mar 21, 2018
Raw hash: 7cabb52cc2797b50f4d5a95280ab04c3b81a2309207afaa288282eaf1ec23e87

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Reporting entityCenter for Comprehensive Services, Inc.

Victim entityCenter for Comprehensive Services, Inc.

IncidentUnauthorized Access

Stated responseEngaged an outside forensics firm to investigate

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing