Top of the World Ranch
bd_6a69fb6630ef6fcb · schema v1 · pii pii-v1
Full breach record for Top of the World Ranch →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 with Top of the World Ranch Treatment Center, LLC (TWRTC) for $103,000 regarding a breach of 1,980 individuals' PHI resulting from an email phishing attack. TWRTC failed to conduct a thorough risk analysis as required by the Security Rule. The resolution agreement includes a Corrective Action Plan requiring risk analysis, risk management, policy updates, and workforce training.
J jump to incidentP pin to compareR raw source
Incident timeline — partial
? — ?
Breach window unknown
Jun 6, 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_45dfa4e8ea70175e2023-03-14 · +815dCandidate
Filing propagation · 2 filings
View merged incident ↗Pattern: first filing Mar 14 (IL), last Jun 6 — a 815-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.