MINNESOTAAccidentalHealthcareHealthcareMisdeliveryBusiness Associate (HIPAA)Customer Data InvolvedDelayed DiscoveryPHIHealth (basic)Identity (basic)MediumResolved

StayWell Health Management, LLC

bd_3d718d17e1f86b30 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jan 21, 2014

Filed

Feb 21, 2014

To disclose

4 weeks

Affected

19,474

Confidence

66%

Full breach record for StayWell Health Management, LLC →4 incidents on file

StayWell Health Management, LLC reported to HHS on 2014-02-21 a Unauthorized Access/Disclosure affecting 19,474 individuals. Breached information located on Network Server. Spreadsheets containing PHI (names, emails, program info) were unintentionally available online in a public-facing folder from March 29, 2012, to January 21, 2014. The BA notified HHS, individuals, and media on behalf of multiple Covered Entities.

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HIPAA clock✓ HHS report on time4 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 · 663 days

discovery → filing · 4 weeks / 31 days

Mar 29, 2012

Begins

Jan 21, 2014

Discovered

Feb 21, 2014

Filed

vs. sector median

7 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed19,474 affectedView incident

Name: StayWell Health Management, LLC
norm: staywell health management
Industry: Health Care Services

Name: StayWell Health Management, LLC
norm: staywell health management
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Jan 21, 2014
Breach occurred: Mar 29, 2012 – Jan 21, 2014
Undetected for: 663 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 19,474nationwide
Data types: PHIHealth (basic)Identity (basic)
HHS breach type: Unauthorized access or disclosure
Where the data lived: Network server
Covered-entity type: Business associate
Attack vector: Unauthorized Access
MITRE ATT&CK: T1041 Exfiltration Over C2 Channel
Threat actor: Internal
Regulator citations: Notified HHSOCR obtained assurances that the BA implemented the corrective actions
Third party: via StayWell Health Management, LLCbusiness associate

During the incident: Upgraded its platform
Revised and implemented its policies and procedures
Restricted access to and to remove the data entirely from Google, Bing, Yahoo, and other search engines
Changes made: Upgraded its platform
Revised and implemented its policies and procedures
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 4 weeks(31 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: Jan 21, 2014
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Jan 21, 2014
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jan 21, 2014 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Jan 21, 2014 → 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: Feb 21, 2014
Raw hash: 24ae87241f48ae8f22da903ffc7453967bb67bfd0f51b0ba223881a58d963ffc

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Reporting entityStayWell Health Management, LLC

Victim entityStayWell Health Management, LLC

Incidentdiscovered Jan 21, 2014

Stated responseUpgraded its platform

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing