American Anesthesiology

The covered entity’s (CE) business associate (BA), Financial Imaging, LLC, erroneously mailed 1,000 patient invoices to the wrong patients. The types of protected health information (PHI) involved in the breach included patients’ names, dates of service, and procedures performed. The BA sent breach notification letters to affected individuals and reimbursed the CE for all costs associated with breach notification it provided to the media. Following the breach, the BA revised its quality assurance process to ensure the accuracy of future print jobs and counseled and retrained the staff involved in the breach. The CE had a BA agreement in place and policies that were in compliance with the HIPAA Rules. OCR obtained assurances that CE and BA implemented the corrective actions listed above.