Change Healthcare (CHC) – HIPAA Breach Notifications

Change Healthcare, owned by UnitedHealth Group, provides services to health care providers, health insurance plans and other companies. In CHC’s role in providing services to providers and plans, personal and/or health information is stored. This role includes the submitting and processing of health insurance claims and pharmacy benefits.

In late February 2024, CHC was a victim of a ransomware attack where it announced that the impacted data could cover a “substantial proportion” of individuals here in the United States. To learn more from CHC, click here

Due to the extensive number of patients that were impacted, HHS released a FAQs page regarding the incident. Those FAQs also include a reminder that covered entities have an obligation to safeguard PHI and the FAQ includes tools to assist with this. HHS also confirmed that the Office of Civil Rights (OCR) initiated an investigation of the breach.

Change Healthcare contacted affected parties regarding the incident and offered to have those parties’ notification duties delegated to Change Healthcare, according to communications received by group health plan administrators on June 20, 2024.

A vast amount of information was compromised in this incident, and affected individuals should be notified to mitigate any potential harm. However, the lack of available information in this case has made it difficult for employers to know who to notify, and what to tell them – and a blanket notification of a potential threat to personal information would likely cause more confusion than clarity. For now, we recommend that employers delegate notification duties to CHC to ensure that their participants get the latest information.


About Michelle Cammayo, Compliance National Practice Leader, Employee Benefits

Michelle Cammayo has close to 20 years of Employee Benefits experience specializing in all lines of health and welfare benefits. Today, Michelle works closely with clients and partners to provide guidance in areas of the law including ERISA, HIPAA, COBRA, FMLA and PPACA. She is also the IMA National Practice Leader for Compliance and endeavors to ensure IMA helps its clients manage and eliminate risk in the most effective manner. She is passionate about educating others and her passion for this shined in the COVID era where Michelle conducted weekly and then monthly webinars providing guidance to employers. Her podcast, Cammayo’s Compliance Talk, has gained popularity in the last three years to become a favorite amongst our clients. She also contributes regularly to our Blog and has authored several articles for industry-related newsletters. Michelle’s consultative approach with employers provides practical advice as employers endeavor to be compliant.

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