In violation of the employer’s policies, a workforce member of the covered entity (CE), Mission City Community Network, Inc., sent an unsecured email to a business associate (BA) containing the protected health information (PHI) of 7,800 individuals. The PHI included names, addresses, dates of birth, and insurance information. During the investigation, OCR determined that the disclosure to the BA for payment purposes was permissible, as the email reached the intended BA, and there was no evidence that PHI was impermissibly disclosed to any other party. OCR provided technical assistance to the CE. As a result of OCR’s investigation, the CE initiated a review and improvements to its HIPAA practices.
