Comprehensive Neurology Specialists
bd_5eeaba582402b435 · schema v1 · pii pii-v1
Full breach record for Comprehensive Neurology Specialists →Regulator's decision — not a breach notification
This record is a regulator's decision, not the organisation's own breach notice. Breach-notification fields (discovery date, notification clock) are structurally absent — what this source establishes is the outcome and the provisions the decision cites.
HHS OCR settled its HIPAA ransomware investigation with Comprehensive Neurology, PC, a single-physician neurology practice in New York. The practice failed to conduct an accurate risk analysis of ePHI vulnerabilities. The incident involved ransomware affecting 6,800 individuals. Comprehensive agreed to pay a $25,000 resolution amount and implement a Corrective Action Plan.
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Incident timeline — partial
? — ?
Breach window unknown
Apr 25, 2025
Filed
—
Corroborated · see linked filings
Compliance clocks stay unassessable until a breach filing is linked. This record is the regulator's action, not a breach notice. Dashed segments fill in automatically when corroboration arrives.
Linked disclosures
Why this link?Regulatory filings (1) · sorted by filing gap
- HHS OCRbd_097711b88f56423c2020-12-17 · +1590dCandidate
Filing propagation · 2 filings
View merged incident ↗Pattern: first filing Dec 17 (NY), last Apr 25 — a 1590-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?
Evidence ladder
Attacker assertion only. Establishes: claim date, group, alleged victim.
Unlocks: incident narrative, operational impact. Still no compliance clock.
Unlocks: discovery date, data types, affected count, compliance clock.
Unlocks: materiality, stated response, full audit trail. Ceiling removed.
Source ceiling
- instrument + outcome
- amount as filed (USD)
- CFR provisions
- the breach it recites
- discovery date
- notification clock
The dates the agreement recites belong to the underlying breach, years earlier, and are kept as evidence of WHICH breach rather than as this record’s timeline.