CALIFORNIAMisuseHealthcareHealthcarePrivilege AbuseCustomer Data InvolvedPHIHealth (basic)Identity (basic)MediumResolved

Palomar Health

bd_6db757f28625306d · schema v1 · pii pii-v1

Severity

Medium

Discovered

Feb 10, 2016

Filed

Jan 8, 2018

To disclose

23 months

Affected

1,309

Confidence

67%

Full breach record for Palomar Health →4 incidents on file

Palomar Health (Palomar Medical Center (Escondido)) reported to HHS on 2018-01-08 a Unauthorized Access/Disclosure affecting 1309 individuals. Breached information located on Electronic Medical Record. An ER nurse accessed patient records without a work-related reason.

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HIPAA clock✗ HHS report late23 months 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

discovery → filing · 23 months / 698 days

Feb 10, 2016

Discovered

Jan 8, 2018

Filed

vs. sector median

+91 wks slower

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed1,309 affectedView incident

Name: Palomar Health
norm: palomar health
Domain: palomarhealth.org
Industry: Health Care Services

Name: Palomar Health
norm: palomar health
Domain: palomarhealth.org
Industry: Healthcaresource default

Discovered: Feb 10, 2016
Materiality determined: —
Notification sent: —
Affected individuals: 1,309nationwide
Data types: PHIHealth (basic)Identity (basic)
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: Internal
Regulator citations: Reported the matter to the Board of Registered Nursing (BRN) and the California Department of Public Health (CDPH)OCR obtained assurances that the CE implemented the corrective actions listed above
Initial access: insider_action

During the incident: Implemented new technical safeguards
Provided individuals with free credit monitoring
Sanctioned the workforce member
Restricted the ER nurse from having access to its facilities, patients, and the electronic medical record
Reported the matter to the Board of Registered Nursing (BRN) and the California Department of Public Health (CDPH)
Circulated an information security awareness sheet related to unauthorized access via email to all employees
Began implementing a new functionality of the Fair Warning tool: a report that runs daily and identifies disproportionate instances of access to patient medical records by staff members
Strengthened and revised its policies and procedures
Performed an assessment
Provided refresher training to all clinical staff regarding proper procedures for administering medication and interacting with automatic medication dispensing machines that contain PHI
New nurses receive training from the Pharmacy Department as part of the new employee orientation
Changes made: Implemented new technical safeguards
Restricted the ER nurse from having access to its facilities, patients, and the electronic medical record
Circulated an information security awareness sheet related to unauthorized access via email to all employees
Began implementing a new functionality of the Fair Warning tool: a report that runs daily and identifies disproportionate instances of access to patient medical records by staff members
Strengthened and revised its policies and procedures
Performed an assessment
Provided refresher training to all clinical staff regarding proper procedures for administering medication and interacting with automatic medication dispensing machines that contain PHI
New nurses receive training from the Pharmacy Department as part of the new employee orientation
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 23 months(698 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: Feb 10, 2016
→ Notified: not extracted
— 60 days HHS report late
HIPAA
Discovered: Feb 10, 2016
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Feb 10, 2016 → Notified: not extracted	—	60 days	HHS report late
HIPAA	Discovered: Feb 10, 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: Jan 8, 2018
Raw hash: 547719600bfeb3e92527077be4649a9e6b758db4fca3155a0dc347c589b88128

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Reporting entityPalomar Health

Victim entityPalomar Health

Incidentdiscovered Feb 10, 2016

Stated responseImplemented new technical safeguards

ComplianceHHS report late

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing