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May 21, 2026

Breach Notification Rule & Incident Response

Breach Notification Rule & Incident Response

This module covers how to recognize and respond to HIPAA security incidents and potential breaches.

What is a breach?

A breach is an impermissible use or disclosure of PHI that compromises its security or privacy — UNLESS one of these exceptions applies:

  • The PHI was encrypted to HIPAA standards AND the decryption key was not compromised, OR
  • An unauthorized person could not reasonably have retained the PHI (e.g., wrong-number call immediately corrected)

When in doubt, report it — the Security Officer determines whether the exception applies.

When to report immediately

Report the same day you discover or suspect:

  • PHI was accessed by an unauthorized person (wrong email, lost device, unauthorized login)
  • A device or account with PHI access was lost or stolen
  • PHI was sent to the wrong recipient
  • Unexpected system activity or unauthorized access detected

How to report

  1. Contact your direct manager immediately
  2. Email Security Officer: j@chimaro.ai
  3. For urgent incidents: contact all above simultaneously via phone

Do not investigate, contain, or remediate alone. Preserve evidence and wait for Security Officer guidance.

Notification timelines (after breach is confirmed)

Recipient Timeline
Affected individuals Within 60 days of discovery
HHS Secretary Within 60 days (add to breach log; annual report if < 500 individuals)
Media (state) Within 60 days if ≥ 500 individuals in a state affected
Customer (Covered Entity) Without unreasonable delay; high-severity: 24 hours

Common incident scenarios

  • Wrong email with PHI attached → Report immediately; document recipient; assess sensitivity
  • Lost/stolen laptop → Report immediately; remotely wipe if available; change all passwords
  • Unauthorized database query → Report immediately; preserve logs; do not query further
  • Phishing credential compromise → Change passwords, revoke tokens, report immediately

Attestation

Completing this module confirms you know how to recognize and report potential HIPAA incidents.


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