Matrix Imaging

The covered entity's (CE) business associate (BA) sent coverage determination letters to incorrect addresses, affecting 2,631 individuals. The protected health information (PHI) included names, addresses, unique CE identification numbers, and prescription drug information. Following the breach, the CE reprinted all erroneous coverage determination letters with an apology notice and provided breach notification to all affected individuals and HHS. The CE implemented additional policies and procedures to ensure mailing list accuracy. Specifically, the CE implemented a multiple-step quality assurance process and established verification with the BA. 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 to safeguard all PHI. As a result of OCR's investigation, the CE placed a record into its accounting of disclosure records for each individual impacted.