ARIZONAHackingHealthcareHealthcareStolen CredentialsCustomer Data InvolvedDelayed DiscoveryHealth (basic)Identity (basic)HighResolved

Valley Anesthesiology Consultants, Inc.

bd_ebf01ca47ea1047c · schema v1 · pii pii-v1

Severity

High

Discovered

Jun 13, 2016

Filed

Aug 12, 2016

To disclose

9 weeks

Affected

882,590

Linked

6 filings

Confidence

95%

Full breach record for Valley Anesthesiology Consultants, Inc. →

Valley Anesthesiology Consultants, Inc. d/b/a Valley Anesthesiology and Pain Consultants (AZ) reported to HHS on 2016-08-12 a Hacking/IT Incident affecting 882,590 individuals. On March 30, 2016, a third party may have gained unauthorized access via remote desktop protocol using accounts with administrator privileges across the CE's network servers. Nine foreign IPs were identified and blacklisted; 15 suspicious local and 3 admin accounts were found potentially compromised. Breached ePHI included demographic and clinical information. OCR provided technical assistance on risk analysis, training, and access controls.

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HIPAA clock✓ HHS report on time9 weeks discovery → filing

Incident timeline

undetected · 75 days

discovery → filing · 9 weeks / 60 days

Mar 30, 2016

Begins

Jun 13, 2016

Discovered

Aug 12, 2016

Filed

vs. sector median

on median

This filing is one of 6 filings about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (5) · sorted by filing gap

Oregon State AGbd_528c463d467fa4dd2016-08-12Candidate
Montana State AGbd_536d1c17f10a57142016-08-12Verified
California State AGbd_62ea62ba052757f32016-08-12Verified
Massachusetts State AGbd_6c09aa6edcca020f2016-08-12Verified

Show 1 more filing ↓

Washington State AGbd_e78919fc3bf148082016-08-12Verified

Name: Valley Anesthesiology Consultants, Inc.
norm: valley anesthesiology consultants
Industry: Health Care Services

Name: Valley Anesthesiology Consultants, Inc.
norm: valley anesthesiology consultants
Industry: Health Care Services
Also named: Valley Anesthesiology Consultants, Inc.dba oflegal entity
Valley Anesthesiology and Pain Consultantsdba oftrade name
Industry: Healthcaresource default

Discovered: Jun 13, 2016
Breach occurred: Mar 30, 2016
Undetected for: 75 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 882,590nationwide
Data types: Health (basic)Identity (basic)
HHS breach type: Hacking / IT incident
Where the data lived: Network server
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1078 Valid AccountsT1021.001 Remote Desktop Protocol
Threat actor: External
Regulator citations: OCR provided technical assistance regarding comprehensive security risk analysis and risk management/mitigation planOCR provided TA regarding security awareness training program documentationOCR requested clarification on user access review procedures for non-ePHI applications
Initial access: external_remote_services

During the incident: Notified HHS, affected individuals, and media
Posted substitute notice per Breach Notification Rule
Engaged forensics firm
Disabled compromised account
Blacklisted malicious IP addresses
Changes made: Disabled the account through which unauthorized access was potentially gained
Blacklisted nine foreign IP addresses at the firewall to block remote desktop protocol access
Forensics firm engaged to investigate breach
Identified and reviewed fifteen suspicious local accounts and three potentially compromised administration accounts
Conducted comprehensive security risk analysis
Implemented security awareness training program improvements
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 9 weeks(60 days from discovery to filing)
Compliance flags: HHS report on timeHHS notified
Discovery-date grounding: letter-groundedThe discovery date is the detection date narrated in the notification letter — the defensible tier.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: Jun 13, 2016
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Jun 13, 2016
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jun 13, 2016 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Jun 13, 2016 → Notified: not extracted	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 6 filings · 6 states

View merged incident ↗

Oregon State AGAug 12 · first

Montana State AGAug 12 · first

California State AGAug 12 · first

Massachusetts State AGAug 12 · first

Washington State AGAug 12 · first

HHS OCRAug 12 · first · this page

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: Aug 12, 2016
Raw hash: 2d87ab69b8357d54741bd5810f682f29896aa5ef8b76ae57be008c9278ff9515

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Linked disclosures

Regulatory filings (5) · sorted by filing gap

Reporting entityValley Anesthesiology Consultants, Inc.

Victim entityValley Anesthesiology Consultants, Inc.

Incidentdiscovered Jun 13, 2016

Stated responseNotified HHS, affected individuals, and media

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing