VIRGINIAMisuseHealthcareHealthcarePrivilege AbuseCustomer Data InvolvedDelayed DiscoveryHealth (basic)Identity (basic)Financial accountMediumResolved

VCU Health System

bd_c79d4cf297455f7e · schema v1 · pii pii-v1

Severity

Medium

Discovered

—

Filed

Jul 6, 2018

To disclose

—

Affected

4,686

Confidence

97%

Full breach record for VCU Health System →

VCU Health System (VA) reported to HHS on 2018-07-06 an Unauthorized Access/Disclosure affecting 4,686 individuals. From January 3, 2003, through May 10, 2018, a staff member accessed PHI without a legitimate business reason; two other employees were aware but did not report it. Breached information, located in Electronic Medical Records, included demographic, financial, and clinical data. All three employees were terminated. OCR obtained assurances of workforce-wide retraining.

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HIPAA clock✓ HHS notified

⚠ no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.

⚠ No discovery dateThe OCR public portal omits the discovery date, so the 60-day notification clock cannot be evaluated from this source — only that the filing was submitted.

Incident timeline

Jan 3, 2003

Begins

Jul 6, 2018

Filed

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed4,686 affectedView incident

Name: VCU Health System
norm: vcu health system
Industry: Health Care Services

Name: VCU Health System
norm: vcu health system
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Not extracted — the OCR public portal omits it
Breach occurred: Jan 3, 2003 – May 10, 2018
Materiality determined: —
Notification sent: —
Affected individuals: 4,686nationwide
Data types: Health (basic)Identity (basic)Financial account
HHS breach type: Unauthorized access or disclosure
Where the data lived: Electronic medical record
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
Threat actor: Internal
Regulator citations: OCR obtained assurances that the CE retrained its entire workforce on its policies and procedures.
Initial access: insider_action

During the incident: Increased safeguards by monitoring all user access and setting alerts for certain types of access.
Sanctioned and terminated the employee who accessed records without a business need.
Sanctioned and terminated two employees who knew of inappropriate access and failed to report it.
Retrained entire workforce on policies and procedures.
Breach notification provided to HHS, affected individuals, and the media.
Changes made: All-staff retraining on HIPAA policies and procedures.
Enhanced user access monitoring with automated alerts.
Termination of three employees involved in or aware of the breach.
Source: Quoted from the filing itself, not independently verified.

Compliance flags: HHS notified
Discovery-date grounding: no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: not extracted
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: not extracted → 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: Jul 6, 2018
Raw hash: 121d0027b7f17caa87fb12b64c4708be9bd16f0adab04f88cff277d30b5e17c3

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Reporting entityVCU Health System

Victim entityVCU Health System

IncidentUnauthorized Access

Stated responseIncreased safeguards by monitoring all user access and setting alerts for certain types of access.

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing