FLORIDAMisuseHealthcareHealthcarePrivilege AbuseCustomer Data InvolvedData ExfiltratedPHIHealth (basic)Identity (basic)Government IDCriticalResolved

Clearway Pain Solutions Institute

bd_4261901d614130da · schema v1 · pii pii-v1

Severity

Critical

Financial impact

$1.19M

Discovered

—

Filed

Apr 5, 2019

To disclose

—

Affected

35,000

Linked

3 filings

Confidence

68%

Full breach record for Clearway Pain Solutions Institute →

Gulf Coast Pain Consultants, LLC d/b/a Clearway Pain Solutions Institute reported to HHS on 2019-04-05 a Unauthorized Access/Disclosure affecting 35000 individuals. Breached information located on Electronic Medical Record. A former contractor impermissibly accessed the system to retrieve PHI for potential fraudulent Medicare claims. The company was fined $1.19 million for HIPAA Security Rule violations.

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HIPAA clock✓ HHS notified

⚠ no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.

⚠ No discovery dateThe OCR public portal omits the discovery date, so the 60-day notification clock cannot be evaluated from this source — only that the filing was submitted.

Incident timeline — partial

? — ?

Breach window unknown

Apr 5, 2019

Filed

—

Corroborated · see linked filings

Compliance clocks stay unassessable until a regulatory filing lands. Dashed segments fill in automatically when corroboration arrives.

This filing is one of 3 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (2) · sorted by filing gap

Massachusetts State AGbd_b0114555473013fe2019-04-08 · +3dVerified
Oregon State AGbd_c01fad1a4fe97c502019-04-11 · +6dVerified

Name: Clearway Pain Solutions Institute
norm: clearway pain solutions institute
Industry: Health Care Services

Name: Clearway Pain Solutions Institute
norm: clearway pain solutions institute
Industry: Health Care Services
Also named: Gulf Coast Pain Consultants, LLCdba oflegal entity
Clearway Pain Solutions Institutedba oftrade name
Industry: Healthcaresource default

Discovered: Not extracted — the OCR public portal omits it
Materiality determined: —
Notification sent: —
Affected individuals: 35,000nationwide
Data types: PHIHealth (basic)Identity (basic)Government ID
HHS breach type: Unauthorized access or disclosure
Where the data lived: Electronic medical record
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: InternalFinancial
Regulator citations: Notified HHS/OCR via breach reportOCR initiated an investigationOCR issued a Notice of Proposed DeterminationOCR imposed a civil money penalty of $1,190,000
Initial access: insider_action

During the incident: Waived its right to a hearing and did not contest OCR’s findings
Paid a civil money penalty of $1,190,000
Changes made: Integrate risk analysis and risk management into business processes
Implement regular review of information system activity
Implement procedures for terminating access to ePHI when the employment of, or other arrangement with, a workforce member ends
Implement procedures for modifying a user’s right of access to a workstation, transaction, program or process, or an alternative equivalent measure
Source: Quoted from the filing itself, not independently verified.

Compliance flags: HHS notified
Discovery-date grounding: no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: not extracted
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: not extracted → Notified: not extracted	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 3 filings · 3 states

View merged incident ↗

HHS OCRApr 5 · first · this page

Massachusetts State AG+3d

Oregon State AG+6d

Pattern: first filing Apr 5 (FL), last Apr 11 (OR) — a 6-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

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 5, 2019
Raw hash: 9b2b3798a5c2b2687399c3657ac11b3815db398d4e035666aac0966073d1942a

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Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityClearway Pain Solutions Institute

Victim entityClearway Pain Solutions Institute

IncidentUnauthorized Access

Stated responseWaived its right to a hearing and did not contest OCR’s findings

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing