Concordia Plan Services

Blue Cross and Blue Shield of Minnesota, a business associate (BA) of Concordia Plan Services on behalf of the Concordia Health Plan, the covered entity (CE), stored the CE’s electronic protected health information (ePHI) on computer servers belonging to its parent corporation, Anthem, Inc. Anthem experienced a series of cyberattacks which exposed the electronic protected health information (ePHI) of almost 79 million people, affecting 12,500 individuals who received health insurance from the CE. The ePHI involved included names, social security numbers, medical identification numbers, addresses, dates of birth, email addresses, and employment information. OCR reviewed the BA agreement and determined that it appeared to comply with the requirements of the HIPAA Privacy and Security Rules. OCR opened a separate review of Anthem, which resulted in Anthem agreeing to pay a monetary settlement and undertaking a robust corrective action plan to comply with the HIPAA Rules.