FLORIDAMalwareHealthcareHealthcareRansomwareBusiness Associate (HIPAA)Customer Data InvolvedData ExfiltratedData EncryptedRansom DemandedPHIHealth (basic)Government IDIdentity (basic)CriticalResolved

Inlandboatmen’s Union of the Pacific National Benefit Fund

bd_f4683e2da8db67bf · schema v1 · pii pii-v1

Severity

Critical

Discovered

Jul 16, 2018

Filed

Aug 22, 2018

To disclose

5 weeks

Affected

502,416

Linked

4 filings

Confidence

67%

Health Management Concepts, Inc. reported to HHS on 2018-08-22 a Hacking/IT Incident affecting 502416 individuals. Breached information located on Network Server. Ransomware encrypted data on a secure sFTP server. ePHI for Inlandboatmen’s Union of the Pacific National Benefit Fund was disclosed to the attacker during decryption negotiations.

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HIPAA clock✓ HHS report on time5 weeks discovery → filing

⚠ unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Incident timeline

discovery → filing · 5 weeks / 37 days

Jul 16, 2018

Discovered

Aug 22, 2018

Filed

vs. sector median

7 wks faster

This filing is one of 4 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (3) · sorted by filing gap

Oregon State AGbd_12623a169504c70a2018-08-22Candidate
Montana State AGbd_9b14b35615fc89232018-08-22Verified
New Hampshire State AGbd_ce92c498079cac1c2018-08-20 · +2dVerified

Name: Health Management Concepts, Inc.
norm: health management concepts
Industry: Health Care Services

Name: Inlandboatmen’s Union of the Pacific National Benefit Fund
norm: inlandboatmen’s union of the pacific national benefit fund
Industry: Healthcaresource default

Discovered: Jul 16, 2018
Materiality determined: —
Notification sent: —
Affected individuals: 502,416nationwide
Data types: PHIHealth (basic)Government IDIdentity (basic)
HHS breach type: Hacking / IT incident
Where the data lived: Network server
Covered-entity type: Business associate
Attack vector: Unauthorized Access
MITRE ATT&CK: T1486 Data Encrypted for ImpactT1041 Exfiltration Over C2 Channel
Threat actor: ExternalFinancial
Third party: via Health Management Concepts, Inc.business associate
Initial access: exploit_public_facing

During the incident: Reset passwords
Installed a new computer server with a new IT host
Reconfigured firewall and remote access procedures
Revised its written breach notification procedures
Engaged a new data backup service
Changes made: Completed a risk analysis in June 2019 to meet the standards of the Security Rule
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 5 weeks(37 days from discovery to filing)
Compliance flags: HHS report on timeHHS notified
Discovery-date grounding: unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: Jul 16, 2018
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Jul 16, 2018
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jul 16, 2018 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Jul 16, 2018 → Notified: not extracted	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 4 filings · 4 states

View merged incident ↗

New Hampshire State AGAug 20 · first

Oregon State AG+2d

Montana State AG+2d

HHS OCR+2d · 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 22, 2018
Raw hash: b266ffac9bbf85604d1973edd24ffbcdd91a779d91a8b59ba686e109749d5c87

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Linked disclosures

Regulatory filings (3) · sorted by filing gap

Reporting entityHealth Management Concepts, Inc.

Victim entityInlandboatmen’s Union of the Pacific National Benefit Fund

Incidentdiscovered Jul 16, 2018

Stated responseReset passwords

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing