A car containing an unencrypted laptop computer was stolen from West Monroe Partners, a contractor for the covered entity's (CE) business associate (BA), DentaQuest. The laptop stored a database containing the electronic protected health information (ePHI) of approximately 76,000 individuals, including data on 10,515 of the CE's members. The types of PHI involved in the breach included names, social security numbers, dates, and certain provider identification numbers. The CE and BA worked together to provide breach notification to affected individuals and the media, and offered free credit monitoring and enhanced credit services to affected individuals for one year. The CE reported the breach to HHS and provided substitute notification on its website. The BA implemented procedures to ensure that any third party laptops connecting to its network employ disk encryption. Further, the BA established a policy to prohibit contractors from storing PHI on laptops. The breach incident involved a BA and occurred prior to the September 23, 2013, compliance date. OCR verified that the CE had a proper BA agreement in place that restricted the BA's use and disclosure of PHI and required the BA t
