Minuteman Senior Services (“MSS”) in Massachusetts notified the U.S. Department of Health and Human Services on January 27 that they experienced a breach affecting 500 patients. The “500” is simply a marker that indicates that the reporting entity knows they have to report a breach to HHS within 60 days of discovery but they do not yet really know how many patients were affected. They only know or estimate that it is more than the 500 trigger to report to HHS.
On their website, MSS writes that on November 30, 2022, they identified suspicious activity related to an employee’s email account. An investigation subsequently determined that the employee’s email account was accessed by an unknown individual between November 21 and November 30, 2022.
MSS has been working with an external data review specialist to identify any personal information in the account and to whom it applies. The types of information that may have been present in the compromised email account could have included: full name, address, date of birth, gender, health insurance information, diagnosis, and service utilization, although the exact data types may vary by individual.
“Once this comprehensive review is complete, MSS will then work to confirm the identities and contact information for potentially impacted individuals and provide notice via a written letter,” they write.
So as of January 27, they had not sent out letters or even completed figuring out who needed to be notified. There is no update on the site indicating whether letters have since gone out.
In response to the incident, MSS writes the usual affirmation of taking the incident and security very seriously:
Upon learning of this event, we immediately secured the impacted email account. As part of our ongoing commitment to the information security, we are enhancing our existing policies and procedures and implementing additional administrative and technical safeguards to further secure the information in our care.
The problem with that assurance, however, is that is exactly what they wrote back in July 2022, after an earlier incident involving the compromise of an employee’s email account. In their July notification, they wrote exactly the same description of their response.
Could the November 2022 compromise of the employee’s email account have been avoided? Was MFA deployed after the July incident? Was staff trained or retrained on phishing? Did all staff do password resets? MSS did not disclose how the employee’s account was compromised in July, nor how an employee’s account was compromised in November. But HHS may consider whether MSS did enough after the first breach to prevent the second breach.
We will eventually learn how many patients the November breach affected. The July 2022 breach affected 4,000 patients.