ILLINOISAccidentalHealthcareHealthcarePublishing ErrorMisuse OtherBusiness Associate (HIPAA)Customer Data InvolvedSupply Chain (3P Vendor)Delayed DiscoveryHealth (basic)Identity (basic)MediumResolved

Integrated Rehab Consultants

bd_1379febb0fb4b575 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Dec 2, 2016

Filed

Apr 9, 2018

To disclose

16 months

Affected

4,292

Confidence

95%

Full breach record for Integrated Rehab Consultants →

On December 2, 2016, a healthcare researcher notified Integrated Rehab Consultants (IL) that its patient data had been inadvertently uploaded to a public GitHub repository by Magnum, a sub-vendor of TrueRCM. The exposure affected 4,292 individuals, involving demographic and clinical (PHI) information. The breach was discovered to have been accessed by at least one additional party in fall 2017. Data was removed from GitHub, TrueRCM terminated Magnum, and HIPAA policies were updated. OCR obtained documented assurances of corrective action. Submitted to HHS on 2018-04-09.

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HIPAA clock✗ HHS report late16 months discovery → filing

⚠ occurrence dateThe stored discovery date equals the breach OCCURRENCE date. Detection is normally later, so this OVERSTATES the delay — a 'late' verdict here may not be real.

Incident timeline

discovery → filing · 16 months / 493 days

Dec 2, 2016

Begins

Dec 2, 2016

Discovered

Apr 9, 2018

Filed

vs. sector median

+58 wks slower

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed4,292 affectedView incident

Name: Integrated Rehab Consultants
norm: integrated rehab consultants
Industry: Health Care Services

Name: Integrated Rehab Consultants
norm: integrated rehab consultants
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Dec 2, 2016
Breach occurred: Dec 2, 2016
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 4,292nationwide
Data types: Health (basic)Identity (basic)
HHS breach type: Unauthorized access or disclosure
Where the data lived: Network server
Covered-entity type: Healthcare providerBusiness associate involved
Attack vector: Unauthorized Access
Threat actor: Partner
Regulator citations: HHS OCR — OCR obtained documented assurances that the CE implemented the corrective actions listed above.
Third party: via Magnum (third-party vendor)

During the incident: Notified HHS, affected individuals, and the media
Posted substitute notice on website
Engaged with business associates to remediate exposure
Changes made: Worked with Magnum to remove the data from the GitHub repository
Confirmed TrueRCM terminated its service relationship with Magnum
Updated HIPAA policies and procedures pertaining to the Breach Notification Rule, safeguards, and business associates
Trained workforce on the revised policies and procedures
Provided breach notification to HHS, affected individuals, and the media; posted substitute notice on its website
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 16 months(493 days from discovery to filing)
Compliance flags: HHS report lateHHS notified
Discovery-date grounding: occurrence dateThe stored discovery date equals the breach OCCURRENCE date. Detection is normally later, so this OVERSTATES the delay — a 'late' verdict here may not be real.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: Dec 2, 2016
→ Notified: not extracted
— 60 days HHS report late
HIPAA
Discovered: Dec 2, 2016
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Dec 2, 2016 → Notified: not extracted	—	60 days	HHS report late
HIPAA	Discovered: Dec 2, 2016 → 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: Apr 9, 2018
Raw hash: e0d02eee73164f96dea3ae3eb00e1322b2dae63da496bc786351ca94dc75f88b

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Reporting entityIntegrated Rehab Consultants

Victim entityIntegrated Rehab Consultants

Incidentdiscovered Dec 2, 2016

Stated responseNotified HHS, affected individuals, and the media

ComplianceHHS report late

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing