Memorial Hermann Health System Employee Group Health Plan
bd_9d968dab31d17c07 · schema v1 · pii pii-v1
Full breach record for Memorial Hermann Health System Employee Group Health Plan →Memorial Hermann Health System (on behalf of its Employee Group Health Plan) reported to HHS OCR on 2016-07-20 an unauthorized disclosure affecting 12,061 plan members. Between December 12, 2015, and May 23, 2016, plan administrator Memorial Hermann Health Solutions impermissibly disclosed PHI — including names, addresses, dates of birth, phone numbers, and member IDs — to primary care physicians with whom members had no existing care relationship. The error originated from a new process implemented in 2014 that was not effectively communicated to Health Plan leadership. Breached information was on Paper/Films.
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Incident timeline
Dec 12, 2015
Begins
Jul 20, 2016
Filed
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.