ILLINOISAccidentalHealthcareHealthcareMisconfigurationBusiness Associate (HIPAA)Customer Data InvolvedDelayed DiscoveryPHIHealth (basic)Identity (basic)MediumResolved

Health Fitness Corporation

bd_fed8e04c67fd98f9 · schema v1 · pii pii-v1

Severity

Medium

Financial impact

$228K

Discovered

Jun 27, 2018

Filed

Oct 28, 2018

To disclose

18 weeks

Affected

614

Linked

4 filings

Confidence

67%

Full breach record for Health Fitness Corporation →2 incidents on file

Health Fitness Corporation reported to HHS OCR on 2018-10-28 a software misconfiguration affecting 614 individuals. ePHI became discoverable on the internet via web crawlers starting in August 2015. The breach was discovered on June 27, 2018. Health Fitness, a business associate, settled with OCR for $227,816 and agreed to a corrective action plan.

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HIPAA clock✗ HHS report late18 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

undetected · 1061 days

discovery → filing · 18 weeks / 123 days

Aug 1, 2015

Begins

Jun 27, 2018

Discovered

Oct 28, 2018

Filed

vs. sector median

+5 wks slower

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

HHS OCRbd_31778e6299a2faed2018-10-15 · +13dVerified
Massachusetts State AGbd_bc2a378cc8c602d12018-10-05 · +23dVerified
HHS OCR enforcementbd_9da38ad954609d452025-03-21 · +2336dVerified by operator

Name: Health Fitness Corporation
norm: health fitness
Industry: Health Care Services

Name: Health Fitness Corporation
norm: health fitness
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Jun 27, 2018
Breach occurred: Aug 1, 2015
Undetected for: 1,061 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 614nationwide
Data types: PHIHealth (basic)Identity (basic)
HHS breach type: Unauthorized access or disclosure
Where the data lived: Other
Covered-entity type: Business associate
Attack vector: Misconfiguration
MITRE ATT&CK: T1190 Exploit Public-Facing Application
Regulator citations: Notified HHS OCRSettlement agreement with OCR

During the incident: Agreed to implement a corrective action plan
Paid $227,816 to OCR
Changes made: Annually reviewing and updating as necessary its risk analysis
Developing and implementing a risk management plan
Implementing a process for evaluating environmental and operational changes
Developing, maintaining, and revising written policies and procedures
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 18 weeks(123 days from discovery to filing)
Compliance flags: HHS report lateHHS 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: Jun 27, 2018
→ Notified: not extracted
— 60 days HHS report late
HIPAA
Discovered: Jun 27, 2018
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jun 27, 2018 → Notified: not extracted	—	60 days	HHS report late
HIPAA	Discovered: Jun 27, 2018 → Notified: not extracted	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 4 filings · 2 states

View merged incident ↗

Massachusetts State AGOct 5 · first

HHS OCR+10d

HHS OCR+23d · this page

HHS OCR enforcement+2359d

Pattern: first filing Oct 5 (MA), last Mar 21 — a 2359-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

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: Oct 28, 2018
Raw hash: 455e48df0b7b075e9b65b42dcac6f87c94fc82f216eedad1f951b16bede15e80

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Linked disclosures

Regulatory filings (3) · sorted by filing gap

Reporting entityHealth Fitness Corporation

Victim entityHealth Fitness Corporation

Incidentdiscovered Jun 27, 2018

Stated responseAgreed to implement a corrective action plan

ComplianceHHS report late

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing