WISCONSINPhysicalHealthcareFinancial ServicesGovernmentHealthcareTheftBusiness Associate (HIPAA)Customer Data InvolvedHealth (basic)Identity (basic)Financial accountLowResolved

Wisconsin Department of Health Services

bd_40fea44ba6b65244 · schema v1 · pii pii-v1

Severity

Low

Discovered

Feb 5, 2018

Filed

Apr 3, 2018

To disclose

8 weeks

Affected

779

Confidence

98%

Full breach record for Wisconsin Department of Health Services →7 incidents on file

On February 5, 2018, a laptop belonging to a business associate (The Management Group's IRIS Consultant) was stolen from her car. The bag also contained a notebook with the laptop's password, rendering the encryption potentially compromised. The laptop may have contained PHI for ~779 individuals enrolled in Wisconsin's IRIS program, including demographic and financial information. The BA reported theft to police, disabled network access, and sanctioned the employee. The CE notified HHS, affected individuals, and media, and offered 12 months of identity theft protection. OCR obtained documented corrective-action assurances.

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HIPAA clock✓ 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

Feb 5, 2018

Begins

Feb 5, 2018

Discovered

Apr 3, 2018

Filed

vs. sector median

1 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed779 affectedView incident

Name: Wisconsin Department of Health Services
norm: wisconsin department of health
Industry: Insurance — Health

Name: Wisconsin Department of Health Services
norm: wisconsin department of health
Industry: Insurance — Health
Industry: Healthcaresource defaultFinancial ServicesllmGovernmentllm

Discovered: Feb 5, 2018
Breach occurred: Feb 5, 2018
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 779nationwide
Data types: Health (basic)Identity (basic)Financial account
HHS breach type: Theft
Where the data lived: Laptop
Covered-entity type: Health planBusiness associate involved
Attack vector: Unauthorized Access· The Management Group IRIS Consultant (employee)
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: Partner
Regulator citations: OCR obtained documented assurances from CE and BA that corrective actions were implemented
Third party: via The Management Groupbusiness associate

During the incident: Reported theft to police
Disabled laptop's capability to connect to the network/system
Sanctioned employee whose laptop was stolen for HIPAA policy violation
Provided breach notification to HHS, affected individuals, and the media
Provided substitute notice on website
Offered 12 months identity theft protection to affected individuals
Changes made: Reviewed and will revise BA contract as appropriate upon renewal
OCR obtained documented assurances that CE and BA implemented corrective actions
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 timeHHS 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: Feb 5, 2018
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Feb 5, 2018
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Feb 5, 2018 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Feb 5, 2018 → 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 3, 2018
Raw hash: d13f3241c332a2ac0180b78fff9d169123e4ed8a5f99bf97ab0bc41f2b499ddf

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Reporting entityWisconsin Department of Health Services

Victim entityWisconsin Department of Health Services

Incidentdiscovered Feb 5, 2018

Stated responseReported theft to police

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing