TEXASAccidentalHealthcareHealthcareDisposal ErrorLossBusiness Associate (HIPAA)Customer Data InvolvedHealth (basic)Financial accountIdentity (basic)MediumResolved

TMA Practice Management Group

bd_e3be53cba2873311 · schema v1 · pii pii-v1

Severity

Medium

Discovered

—

Filed

Mar 17, 2014

To disclose

—

Affected

2,260

Confidence

95%

Full breach record for TMA Practice Management Group →

TMA Practice Management Group (Business Associate, TX) reported to HHS OCR on 2014-03-17 an Improper Disposal/Loss breach affecting 2,260 individuals. McBroom Clinic, PA (the covered entity) copied patient PHI — including clinical and insurance/payment information — to an unencrypted USB flash drive and sent it to the BA on January 7, 2014. The BA received an empty package and discarded it. Breached information was located on an Other Portable Electronic Device. OCR investigation prompted encryption procedures, risk analysis, and staff training improvements.

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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 7, 2014

Begins

Mar 17, 2014

Filed

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed2,260 affectedView incident

Name: TMA Practice Management Group
norm: tma practice management

Name: TMA Practice Management Group
norm: tma practice management
Industry: Healthcaresource default

Discovered: Not extracted — the OCR public portal omits it
Breach occurred: Jan 7, 2014
Materiality determined: —
Notification sent: Feb 21, 2014
Affected individuals: 2,260nationwide
Data types: Health (basic)Financial accountIdentity (basic)
HHS breach type: Improper disposalLoss
Where the data lived: Portable electronic device
Covered-entity type: Business associate
Attack vector: Misconfiguration
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: Partner
Regulator citations: OCR investigation conducted; CE advised on risk analysis improvements and staff training on policies and procedures
Third party: via TMA Practice Management Groupbusiness associate
Initial access: removable_media

During the incident: Contracted AllClear ID on or around February 21, 2014 for patient notification and mitigation
OCR investigation conducted
Changes made: CE instituted new procedures for extracting and sending PHI via portable media, including encryption
Contracted AllClear ID to assist with patient notification and mitigation efforts
Risk analysis improvements identified by OCR
Staff training on policies and procedures identified by OCR
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: Feb 21, 2014
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: not extracted → Notified: Feb 21, 2014	—	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 17, 2014
Raw hash: 480a84c1e6b9aa4c2dd867dba2f8172b878fcb289c9a4ddea31890bb277d3bcf

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Reporting entityTMA Practice Management Group

Victim entityTMA Practice Management Group

IncidentMisconfiguration

Stated responseContracted AllClear ID on or around February 21, 2014 for patient notification and mitigation

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing