Service Benefits Plan Administrative Services

The covered entity's (CE) business associate (BA) incorrectly updated contract holders' addresses and mailed protected health information (PHI) to the wrong address of approximately 3,400 individuals. The PHI involved included demographic information, explanations of benefits, clinical information, and diagnoses. The breach incident involved a BA and occurred prior to the September 23, 2013, compliance date. Upon discovery of the breach, the CE obtained assurances that the BA took steps to enforce the requirements of the BA agreement. Specifically, the BA updated its processes and created an incident tracking report. In addition, a contract was executed for a new vendor to handle mail address verification. Following OCR's investigation, the BA improved its code review process to catch the system error that caused this incident and instituted a manual quality review process. 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. \ \