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[Expert Solution]: Walnut Grove Hospital outsources some…

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Walnut Grove Hospital outsources some inpatient coding to Waldorf and Associates, with whom they have a business associate agreement. Eloise Apple is an independent coding consultant who works for Waldorf and Associates and is primarily responsible for coding the accounts from Walnut Grove Hospital. She has her own business associate agreement with Waldorf and Associates. AB125118_Ch07_Domain VII_AK_online.indd 383 12/5/2019 10:12:34 AM Eloise’s consulting business grew faster than she expected, so she subcontracted the work from Waldorf and Associates to Astor C. Elery but did not initiate a business associate agreement with her. Unfortunately, Astor was a victim of voice phishing (vishing) when, on April 2nd, she received what she thought was a legitimate call from the hospital’s IT department wanting to verify her log-in credentials after a virus was detected. The caller, who presented himself as an IT represen tative, stated he needed the information in order to validate that the virus had not originated from her computer. Once the caller had Astor’s access information, he was able to enter the hospital information system at will. He used it to locate the account of a prominent individual within the community, which included details about her recent venereal disease diagnosis. Two days after the vishing incident, the woman received a blackmail letter and immediately reported it to the police. They began an investigation to determine who the blackmailer was and from where the information had been obtained. That led them to the hospital and her primary care physician. After the hospital’s IT department performed analysis of their system, it was clear the information had come from them, and specifically under the log-in of Astor 1. From the evidence above, did a breach truly occur? Support your position. 2. Based on the above information, will any notifications be necessary? Why or why not?

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