Merkle Direct Marketing

The covered entity's (CE) business associate (BA) mailed protected health information (PHI) of approximately 15,000 individuals to incorrect addresses due to an error in its quarterly address update process. The mailing contained demographic information, explanations of benefits, clinical information, and diagnoses. Upon discovery of the breach, the CE collected the returned mail and verified that it had not been delivered, and updated its HIPAA policies and procedures. Following OCR's investigation, the CE was able to recover all or nearly all of the misdirected envelopes.