Pathway to Hope

The covered entity (CE), Pathway to Hope, discovered in January 2015, that a former employee emailed the protected health information (PHI) of 600 individuals to her personal email account, before her last day of employment with the CE for the purpose of building her own practice. The types of PHI in the email included the full names, referral sources, insurance information, and general diagnoses/conditions (i.e. mental health/substance abuse). The CE provided breach notification to HHS and to affected individuals. Media notice was not required. OCR provided technical assistance to the CE regarding the Privacy, Security and Breach Notification Rules. In response to the breach, the CE counseled workforce members, improved its training program, substantially revised its policies and procedures, hired a compliance officer, and began requiring that employees sign non-compete, non-solicitation confidentiality agreements. OCR obtained assurances that the CE implemented the corrective actions listed above.