Gulf Coast Pain Consultants, LLC d/b/a Clearway Pain Solutions Institute
bd_ace50d0a0df6380f · schema v1 · pii pii-v2
Full breach record for Gulf Coast Pain Consultants, LLC d/b/a Clearway Pain Solutions Institute →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 imposed a $1.19M civil money penalty on Gulf Coast Pain Consultants for Security Rule violations. A former contractor impermissibly accessed ePHI of ~34,310 individuals for potential Medicare fraud. Violations included failure to conduct risk analysis, review activity logs, and terminate former workforce access.
P pin to compareR raw source
Incident timeline — partial
? — ?
Breach window unknown
Dec 3, 2024
Filed
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No linked breach filing · watching
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.
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.