Supply chain β›“ Supply Chain

HIPAA Journal

πŸ“… 2017-12-01 🏒 Undisclosed transcription service provider
Primary Source β†—

Incident Details

Orlando Orthopaedic Center reported a breach of 19,101 patient records caused by an error made by its third-party transcription service provider during a software upgrade in December 2017. The vendor misconfigured access controls on a server during the update, inadvertently exposing the database containing patient protected health information (PHI) to unauthorized access for approximately two months. The exposed data included patient names, dates of birth, insurance information, employer details, and treatment types. A limited number of patients also had their Social Security numbers exposed. The breach was particularly notable for the significant delays in reporting and notification that followed its discovery. Orlando Orthopaedic Center filed its breach report with the Department of Health and Human Services Office for Civil Rights (OCR) on July 20, 2018 – approximately five months after the breach was discovered. Patient notification letters were not sent until approximately six months after discovery. Under HIPAA Breach Notification Rule requirements, covered entities and their business associates must notify the OCR and affected individuals within 60 days of discovering a breach, making both notifications significantly overdue. The incident highlighted two critical supply-chain security issues in healthcare. First, the reliance on third-party transcription vendors who handle sensitive PHI creates risk when those vendors perform system changes without adequate security controls or testing. Second, the delayed notification chain – from vendor to covered entity to regulators and patients – demonstrated how third-party relationships can compound breach response failures. The transcription vendor’s error during a routine software upgrade exposed a fundamental gap in change management procedures for systems handling protected health information.

Technical Details

Initial Attack Vector
Transcription vendor misconfigured database access during software upgrade
Vendor / Product
Undisclosed transcription service provider
Supply Chain Attack
βœ… Confirmed third-party / vendor compromise

Timeline

  1. 2017-12-01 Breach occurred
  2. 2018-07-20 Publicly disclosed
  3. 2018-08-01 Customers notified