KENTUCKYMisuseHealthcareHealthcarePrivilege AbuseBusiness Associate (HIPAA)Customer Data InvolvedData ExfiltratedDelayed DiscoveryPHIHealth (basic)Government IDIdentity (basic)Financial accountCriticalResolved

Commonwealth Health Corporation

bd_ceceaa3096197646 · schema v1 · pii pii-v1

Severity

Critical

Discovered

—

Filed

Mar 1, 2017

To disclose

—

Affected

697,800

Confidence

66%

Full breach record for Commonwealth Health Corporation →

Commonwealth Health Corporation reported to HHS on 2017-03-01 a Unauthorized Access/Disclosure affecting 697800 individuals. Breached information located on Other Portable Electronic Device. An employee impermissibly disclosed PHI of 117,425 patients to a vendor in August 2014 and February 2015. Individual notifications were delayed until March 2017 due to law enforcement delay.

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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

Aug 1, 2014

Begins

Mar 1, 2017

Filed

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed697,800 affectedView incident

Name: Commonwealth Health Corporation
norm: commonwealth health
Industry: Health Care Services

Name: Commonwealth Health Corporation
norm: commonwealth health
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Not extracted — the OCR public portal omits it
Breach occurred: Aug 1, 2014 – Feb 28, 2015
Materiality determined: —
Notification sent: Mar 21, 2017
Affected individuals: 697,800nationwide
Data types: PHIHealth (basic)Government IDIdentity (basic)Financial account
HHS breach type: Unauthorized access or disclosure
Where the data lived: Portable electronic device
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: Internal
Regulator citations: sent timely breach notification to HHSOCR provided technical assistance regarding safeguards for reactivating users in its IT systemOCR obtained assurances that the CE implemented the corrective actions listed above
Initial access: insider_action

During the incident: Sanctioned the party responsible for the breach
Retrained staff
Adopted new policies and procedures
Revised existing policies and procedures
Formalized existing procedures that were not previously in writing
Changes made: Retrained staff
Adopted new policies and procedures
Revised existing policies and procedures
Formalized existing procedures that were not previously in writing
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: Mar 21, 2017
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: not extracted → Notified: Mar 21, 2017	—	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 1, 2017
Raw hash: da348ca88881ec1ace6f1ba51dd04c178cd69a54003ce4accb114702f3cce65f

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Reporting entityCommonwealth Health Corporation

Victim entityCommonwealth Health Corporation

IncidentUnauthorized Access

Stated responseSanctioned the party responsible for the breach

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing