CALIFORNIAAccidentalHealthcareHealthcareMisdeliveryCustomer Data InvolvedPHIHealth (basic)Identity (basic)MediumResolved

VA Northern California Health Care System

bd_9e4ef640518f9acd · schema v1 · pii pii-v1

Severity

Medium

Discovered

Dec 1, 2017

Filed

Mar 26, 2018

To disclose

16 weeks

Affected

1,600

Confidence

66%

Full breach record for VA Northern California Health Care System →2 incidents on file

VA Palo Alto Health Care System reported to HHS on 2018-03-26 a Unauthorized Access/Disclosure affecting 1600 individuals. Breached information located on Paper/Films. During a mass mailing to recruit for a research study, a worker used an electronic mail merge and mixed up names and addresses on mailed postcards containing PHI.

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HIPAA clockDiscovered Dec 1, 2017 → Notified Mar 26, 2018115d ✗ HHS report late16 weeks discovery → filing

⚠ occurrence dateThe stored discovery date equals the breach OCCURRENCE date. Detection is normally later, so this OVERSTATES the delay — a 'late' verdict here may not be real.

Incident timeline

discovery → filing · 16 weeks / 115 days

Dec 1, 2017

Begins

Dec 1, 2017

Discovered

Mar 26, 2018

Filed

vs. sector median

+6 wks slower

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed1,600 affectedView incident

Name: VA Northern California Health Care System
norm: va northern california health care system
Industry: Health Care Services

Name: VA Northern California Health Care System
norm: va northern california health care system
Industry: Healthcaresource default

Discovered: Dec 1, 2017
Breach occurred: Dec 1, 2017 – Dec 31, 2017
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 26, 2018
Affected individuals: 1,600nationwide
Data types: PHIHealth (basic)Identity (basic)
HHS breach type: Unauthorized access or disclosure
Where the data lived: Paper / films
Covered-entity type: Healthcare provider
Attack vector: Misconfiguration
MITRE ATT&CK: T1530 Data from Cloud Storage
Threat actor: Internal
Regulator citations: Notified HHSOCR obtained assurances that the VA took voluntary corrective action

During the incident: Re-sending the postcards correctly
Training research study staff on proper handling of PHI and on the mail merge system
Revising its procedure so that a second person checks mail merged documents against a master list before mailing
Changes made: Training research study staff on proper handling of PHI and on the mail merge system
Revising its procedure so that a second person checks mail merged documents against a master list before mailing
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 16 weeks(115 days from discovery to filing)
Compliance flags: HHS report late · 115dHHS notified
Discovery-date grounding: occurrence dateThe stored discovery date equals the breach OCCURRENCE date. Detection is normally later, so this OVERSTATES the delay — a 'late' verdict here may not be real.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: Dec 1, 2017
→ Notified: Mar 26, 2018
115d 60 days HHS report late
HIPAA
Discovered: Dec 1, 2017
→ Notified: Mar 26, 2018
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Dec 1, 2017 → Notified: Mar 26, 2018	115d	60 days	HHS report late
HIPAA	Discovered: Dec 1, 2017 → Notified: Mar 26, 2018	—	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: Mar 26, 2018
Raw hash: d5345afa173ea8f2833793289764a14a6a5fbf47c711bfda9d44095621a50c2f

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Reporting entityVA Northern California Health Care System

Victim entityVA Northern California Health Care System

Incidentdiscovered Dec 1, 2017

Stated responseRe-sending the postcards correctly

ComplianceHHS report late

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing