Cheyenne Regional Medical snapper in wyoming has posted a data certificate incident notice on its website. According to the notice, on or about april 5, 2019, CRMC became aware of suspicious action related to certain employee payroll accounts and launched an investigation. They ultimately determined that some CRMC employee accounts were accessed without authorization between march 27, 2019 and april 8, 2019. Unfortunately, the investigation was not able to determine which files, if any, were actually accessed or viewed during the affected time period. CRMC believes that the goal of the attackers was to advance access to employee payroll information, but cannot rule out the possibility that patient information in the employees’ email accounts was (also) targeted. It wasn’t until November 1, 2019 that their retrospect of all the suspect email accounts was completed but they allay did not make middleman addresses for those who would demand to be contacted. Interestingly — and a bit untypically — CRMC explains why there was patient info in the employee email accounts: CRMCs policies and standard procedures dictate that patient info in our care be stored securely in our electronic health records system; however, based on necessary consultations and for administrative purposes, certain info is also exchanged among our staff and with other providers via email. All such email exchanges are made securely in accordance with CRMC procedures. CRMCs investigation confirmed the info present within the impacted email accounts at the time of the incident may include patient name, date of birth, Social Security number, drivers licence number, dates of service, provider name, medical record number, patient identification number, medical information, diagnosis, treatment information, health insurance information, and for a very small number of individuals, credit card information and/or financial account information. You can scan the entire observation here, and will also feel FAQs on the transgress on that url. CRMC arranged with Kroll to supply services to those affected, but what I really noted was their detailed timeline of the steps in their incident response. You can find the details on their website notice, but it’s clear that they had to explain why it has taken 8 months since they first became aware of suspicious activity until now to make notifications. And if you come their chronology, then you may be left wondering whether HHS’s 60-day formula is unreasonable. Or if it’s reasonable, then explain what CRMC could have or should have done differently in their pre-incident planning and/or incident response that would get enabled them to make notifications within 60 days of discovery of the breach.