Molina Healthcare of New Mexico

On behalf of the covered entity (CE), Molina Healthcare of California Partner Plan, Inc., a business associate (BA) subcontractor, printed and mailed postcards to the CE’s former members addressed generically to “Resident” and containing a tracking number, that in some cases, was the member’s social security number. Approximately 4,744 individuals were affected by this breach. The CE provided breach notification to HHS, affected individuals, and the media and posted substitute notification on its website. It also offered affected individuals one year of free identity theft protection services. As a result of the incident, the CE revised and developed HIPAA policies and procedures to better safeguard protected health information (PHI) during mailing projects. It also counseled the workforce members involved in the incident pursuant to its policies. OCR obtained assurances that the CE implemented the corrective actions listed above.