Elbowoods Memorial Health Center

On or about October 1, 2011 contractors discovered abandoned protected health information (PHI) at the Mandan, Hidatsa, and Arikara Nations’ Minne-Tohe facility. Materials included cardboard boxes, file cabinets, and binders containing printed PHI; pharmaceutical bags containing printed PHI on medication containers in a caged area with a broken or open padlock; and twelve (12) computer towers, three (3) mini-sized computers, and a lap-top hard drive containing electronic PHI. The covered entity (CE), discovered an additional binder of PHI on May 15, 2013. The CE estimated that 10,000 individuals’ PHI was stored at Minne-Tohe prior to a move to the Elbowoods Memorial Health Center facility. OCR provided the CE with substantial technical assistance. As a result of OCR’s investigation, the CE relocated the stored materials to its new facility, conducted a risk analysis, developed a risk management plan, and developed policies and procedures to safeguard PHI.