Oklahoma State University: 279,865 individuals, Jan 2018.

Oklahoma State University - Center for Health Sciences (OSU-CHS) has paid $875,000 to the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) and agreed to implement a corrective action plan to settle potential violations of the Health Insurance Portability and Accountability Act (HIPAA) Privacy, Security, and Breach Notification Rules. OSU-CHS is a public land-grant research university which provides preventive, rehabilitative, and diagnostic care in Oklahoma.

On January 5, 2018, OSU-CHS filed a breach report stating that an unauthorized third party gained access to a web server that contained electronic protected health information (ePHI). The hacker installed malware that resulted in the disclosure of the ePHI of 279,865 individuals, including their names, Medicaid numbers, healthcare provider names, dates of service, dates of birth, addresses, and treatment information. OSU-CHS initially reported that the breach occurred on November 7, 2017, but later reported that the ePHI was first impermissibly disclosed on March 9, 2016.

OCR's investigation found potential violations of the HIPAA Rules including impermissible uses and disclosures of PHI; failure to conduct an accurate and thorough risk analysis; failure to perform an evaluation, failures to implement audit controls, security incident response and reporting, and failure to provide timely breach notification to affected individuals and HHS.

"HIPAA covered entities are vulnerable to cyber-attackers if they fail to understand where ePHI is stored in their information systems," said OCR Director Lisa J. Pino. "Effective cybersecurity starts with an accurate and thorough risk analysis and implementing all of the Security Rule requirements."

In addition to the monetary settlement, OSU-CHS will undertake a robust corrective action plan that includes two years of monitoring. A copy of the resolution agreement and corrective action plan may be found at: https://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/agreements/osu-ra-cap/index.html.