FLORIDAHackingHealthcareHealthcareBusiness Associate (HIPAA)Customer Data InvolvedData ExfiltratedPHIHealth (basic)Identity (basic)Government IDHighContained

Medical Information Management Systems, LLC

bd_5de38dcc9a6937e9 · schema v1 · pii pii-v1

Severity

High

Discovered

Jun 13, 2016

Filed

Feb 9, 2017

To disclose

34 weeks

Affected

11,707

Confidence

66%

Full breach record for Medical Information Management Systems, LLC →

Medical Information Management Systems, LLC reported to HHS on 2017-02-09 a Hacking/IT Incident affecting 11707 individuals. Breached information located on Network Server. A third party gained unauthorized access to the network, including the BA's server, on March 30, 2016. The incident compromised ePHI including patient names, DOBs, addresses, health insurance info, clinical info, and SSNs.

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HIPAA clock✗ HHS report late34 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 · 75 days

discovery → filing · 34 weeks / 241 days

Mar 30, 2016

Begins

Jun 13, 2016

Discovered

Feb 9, 2017

Filed

vs. sector median

+22 wks slower

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed11,707 affectedView incident

Name: Medical Information Management Systems, LLC
norm: medical information management
Industry: Health Care Services

Name: Medical Information Management Systems, LLC
norm: medical information management
Industry: Healthcaresource default

Discovered: Jun 13, 2016
Breach occurred: Mar 30, 2016
Undetected for: 75 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 11,707nationwide
Data types: PHIHealth (basic)Identity (basic)Government ID
HHS breach type: Hacking / IT incident
Where the data lived: Network server
Covered-entity type: Business associate
Attack vector: Unauthorized Access
MITRE ATT&CK: T1190 Exploit Public-Facing Application
Threat actor: External
Regulator citations: Notified HHS (notice was not timely)OCR provided technical assistance regarding the BA’s obligations to conduct a comprehensive and current security risk analysis and implement a corresponding risk management/mitigation plan
Third party: via Valley Anesthesiology and Pain Consultantsbusiness associate
Initial access: exploit_public_facing

During the incident: Installed a virtual privacy network (VPN) device to improve the security of remote access to the network
Disabled the compromised network accounts
“Blacklisted” the internet addresses identified in the incident to block any additional attempts from those actors to access the electronic health record program (EHR) through the remote desktop protocol
Rebuilt the compromised server
Implemented centralized logging for key systems
Whitelisted service provider internet addresses
Switched their antivirus and EHR programs
Changes made: Conducted a comprehensive and current security risk analysis
Implemented a corresponding risk management/mitigation plan to address any findings
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 34 weeks(241 days from discovery to filing)
Compliance flags: HHS report lateHHS 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: Jun 13, 2016
→ Notified: not extracted
— 60 days HHS report late
HIPAA
Discovered: Jun 13, 2016
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jun 13, 2016 → Notified: not extracted	—	60 days	HHS report late
HIPAA	Discovered: Jun 13, 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: Feb 9, 2017
Raw hash: 7bcf8acb18b4315e7da40c353f01d70f51e98e53642b71fba380b6b2211070d4

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Reporting entityMedical Information Management Systems, LLC

Victim entityMedical Information Management Systems, LLC

Incidentdiscovered Jun 13, 2016

Stated responseInstalled a virtual privacy network (VPN) device to improve the security of remote access to the network

ComplianceHHS report late

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing