FLORIDAMisuseHealthcareHealthcarePrivilege AbuseCustomer Data InvolvedEmployee Data InvolvedIdentity (basic)Health (basic)Financial accountLowResolved

Consultants in Neurological Surgery, LLP

bd_3bebcbc1d1476796 · schema v1 · pii pii-v1

Severity

Low

Discovered

Sep 9, 2016

Filed

Nov 8, 2016

To disclose

9 weeks

Affected

800

Confidence

97%

Full breach record for Consultants in Neurological Surgery, LLP →

Consultants in Neurological Surgery, LLP (FL) reported to HHS on 2016-11-08 an Unauthorized Access/Disclosure affecting 800 individuals. Breached information located on Paper/Films. An employee was discovered on September 9, 2016 to have stolen patients' credit card information for personal use while processing co-payments, also accessing demographic and clinical information. The employee was terminated, and the CE revised policies, retrained staff, and limited data in its practice management software. OCR provided technical assistance and obtained assurances of corrective action.

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HIPAA clock✓ HHS report on time9 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

discovery → filing · 9 weeks / 60 days

Sep 9, 2016

Discovered

Nov 8, 2016

Filed

vs. sector median

4 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed800 affectedView incident

Name: Consultants in Neurological Surgery, LLP
norm: consultants in neurological surgery
Industry: Health Care Services

Name: Consultants in Neurological Surgery, LLP
norm: consultants in neurological surgery
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Sep 9, 2016
Materiality determined: —
Notification sent: —
Affected individuals: 800nationwide
Data types: Identity (basic)Health (basic)Financial account
HHS breach type: Unauthorized access or disclosure
Where the data lived: Paper / films
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: InternalFinancial
Regulator citations: OCR provided technical assistance regarding the Breach Notification Rule and the Security RuleOCR obtained assurances that the CE implemented corrective actions
Initial access: insider_action

During the incident: Altered policies for handling credit card payments
Limited types of information maintained in practice management software
Retrained workforce
Revised policies and procedures
Sanctioned and terminated involved employee
Changes made: Policy changes for credit card payment handling
Restricted data access in practice management software
Workforce retraining
Policy and procedure revisions
Employee termination
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 9 weeks(60 days from discovery to filing)
Compliance flags: HHS report on timeHHS 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: Sep 9, 2016
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Sep 9, 2016
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Sep 9, 2016 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Sep 9, 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: Nov 8, 2016
Raw hash: db350d98e42c3c764cd9f995dd51c4d2466c8cc51a2a0d926331191fd6a1b86d

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Reporting entityConsultants in Neurological Surgery, LLP

Victim entityConsultants in Neurological Surgery, LLP

Incidentdiscovered Sep 9, 2016

Stated responseAltered policies for handling credit card payments

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing