Sloane Stecker Physical Therapy

A workforce member, a physical therapist, accessed the electronic health record system and obtained 2,000 patients’ names, addresses and telephone numbers for the purpose of contacting or soliciting these patients to join a new physical therapy practice. The covered entity (CE), Sloane Stecker Physical Therapy, PC, provided breach notification to HHS, affected individuals, and the media and posted substitute notice on its website. The also CE provided free credit monitoring for the affected individuals. Following the breach, the CE retrieved the patient information and retrained staff. As a result of OCR’s investigation and technical assistance, the CE is expected to perform an enterprise-wide risk analysis and establish a risk management plan. It is also expected to implement mechanisms to record and examine activity in information systems that contain or use electronic PHI. Additionally, the CE is expected to implement a security incident policy and procedure, implement procedures for identity verification for access to electronic PHI, and provide training to all staff on the newly implemented policies and procedures.