MICHIGANAccidentalHealthcareHealthcareMisdeliveryCustomer Data InvolvedPHIHealth (basic)Identity (basic)Government IDMediumResolved

Orchid MPS Holdings, LLC Welfare Benefit Plan

bd_3deb3344c8b7c27c · schema v1 · pii pii-v1

Severity

Medium

Discovered

Mar 30, 2016

Filed

May 26, 2016

To disclose

8 weeks

Affected

771

Confidence

66%

Full breach record for Orchid MPS Holdings, LLC Welfare Benefit Plan →

Orchid MPS Holdings, LLC Welfare Benefit Plan reported to HHS on 2016-05-26 a Unauthorized Access/Disclosure affecting 771 individuals. Breached information located on Paper/Films. A vendor improperly disclosed PHI by mailing IRS Forms 1095-C to wrong recipients.

J jump to incidentP pin to compareR raw source

HIPAA clockDiscovered Mar 30, 2016 → Notified May 26, 201657d ✓ HHS report on time8 weeks 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 · 8 weeks / 57 days

Mar 30, 2016

Begins

Mar 30, 2016

Discovered

May 26, 2016

Filed

vs. sector median

4 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed771 affectedView incident

Name: Orchid MPS Holdings, LLC Welfare Benefit Plan
norm: orchid mps holdings llc welfare benefit plan
Industry: Insurance — Health

Name: Orchid MPS Holdings, LLC Welfare Benefit Plan
norm: orchid mps holdings llc welfare benefit plan
Industry: Healthcaresource default

Discovered: Mar 30, 2016
Breach occurred: Mar 30, 2016
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: May 26, 2016
Affected individuals: 771nationwide
Data types: PHIHealth (basic)Identity (basic)Government ID
HHS breach type: Unauthorized access or disclosure
Where the data lived: Paper / films
Covered-entity type: Health plan
Attack vector: Misconfiguration
MITRE ATT&CK: T1530 Data from Cloud Storage
Threat actor: Internal
Regulator citations: Notified HHSOCR obtained documented assurances that the CE implemented corrective actions

During the incident: Provided breach notification to HHS and affected individuals
Instructed employees to return 1095-C forms to Human Resources
Provided free credit monitoring and identity theft protection to affected individuals
Terminated contract with the vendor that caused the breach
Entered into a business associate agreement with a new vendor
Changes made: Implemented additional procedures to reduce the incidence of error in the 1095-C reporting process
Personally distributed forms to current employees
Ensured forms contain only the minimum necessary information
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 8 weeks(57 days from discovery to filing)
Compliance flags: HHS report on time · 57dHHS 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: Mar 30, 2016
→ Notified: May 26, 2016
57d 60 days HHS report on time
HIPAA
Discovered: Mar 30, 2016
→ Notified: May 26, 2016
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Mar 30, 2016 → Notified: May 26, 2016	57d	60 days	HHS report on time
HIPAA	Discovered: Mar 30, 2016 → Notified: May 26, 2016	—	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: May 26, 2016
Raw hash: 3ccffd4caef8f9b00201bfa9babe27424f994f2e0acfeb29cfebaa127faa6a58

AI-assisted summary above. The structured extract on this page was generated from the document below. Inspect the source to verify or correct any field.

text/html2.0 KB

Download View at source

Reporting entityOrchid MPS Holdings, LLC Welfare Benefit Plan

Victim entityOrchid MPS Holdings, LLC Welfare Benefit Plan

Incidentdiscovered Mar 30, 2016

Stated responseProvided breach notification to HHS and affected individuals

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing