MISSOURIAccidentalHealthcareFinancial ServicesHealthcareMisdeliveryCustomer Data InvolvedEmployee Data InvolvedIdentity (basic)Government IDHealth (basic)HighResolved

Hogan Services Inc. Health Care Premium Plan

bd_e790eabf81a9e264 · schema v1 · pii pii-v1

Severity

High

Discovered

Mar 30, 2012

Filed

May 11, 2012

To disclose

6 weeks

Affected

1,134

Confidence

97%

Full breach record for Hogan Services Inc. Health Care Premium Plan →

On March 30, 2012, Hogan Services Inc. (HSI), sponsor of a fully insured employee health plan (MO), erroneously emailed ePHI of approximately 1,134 individuals to 287 employees. Exposed data included names, SSNs, dates of birth, gender, plan IDs, member IDs, enrollment dates, coverage types, and dependent relationship info. HSI shut down its email server, deleted ePHI from workstations, shredded printed copies, and notified HHS and affected individuals. Following OCR investigation, HSI ceased ePHI handling, retrained staff, and deployed encryption. Breached information located on Email.

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HIPAA clock✓ HHS report on time6 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 · 6 weeks / 42 days

Mar 30, 2012

Begins

Mar 30, 2012

Discovered

May 11, 2012

Filed

vs. sector median

6 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed1,134 affectedView incident

Name: Hogan Services Inc. Health Care Premium Plan
norm: hogan services inc health care premium plan
Industry: Insurance — Health

Name: Hogan Services Inc. Health Care Premium Plan
norm: hogan services inc health care premium plan
Industry: Insurance — Health
Industry: Healthcaresource defaultFinancial Servicesllm

Discovered: Mar 30, 2012
Breach occurred: Mar 30, 2012
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 1,134nationwide
Data types: Identity (basic)Government IDHealth (basic)
HHS breach type: Unauthorized access or disclosure
Where the data lived: Email
Covered-entity type: Health plan
Attack vector: Unauthorized Access
Threat actor: Internal
Regulator citations: OCR investigation completed; OCR obtained assurances that HSI implemented corrective actions.
Initial access: insider_action

During the incident: Directed email vendor to shut down its email server.
Constructed an incident response team that visited each workstation and deleted ePHI from employees' computers.
Shredded any printed copies of the erroneous email.
Provided breach notification to HHS and affected individuals.
Decided not to accept, store, or transmit ePHI going forward.
Retrained workforce regarding HIPAA Rules.
Added encryption software to employee accounts with access to ePHI.
Changes made: Workforce HIPAA retraining conducted.
Encryption software added to relevant employee accounts.
Policy decision to cease ePHI acceptance, storage, and transmission.
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 6 weeks(42 days from discovery to filing)
Compliance flags: HHS report on timeHHS 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: Mar 30, 2012
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Mar 30, 2012
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Mar 30, 2012 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Mar 30, 2012 → 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: May 11, 2012
Raw hash: 787bdc7b2a8e1f9b22df28f381e99e204b716af52ca4c60fc630f6e90fd94aa9

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Reporting entityHogan Services Inc. Health Care Premium Plan

Victim entityHogan Services Inc. Health Care Premium Plan

Incidentdiscovered Mar 30, 2012

Stated responseDirected email vendor to shut down its email server.

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing