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The Colorado Department of Health Care Policy & Financing (HCPF) has not substantiated a four-million-person impact from its MOVEit incident. Its 2023 notice says certain files containing information about some Health First Colorado and Child Health Plan Plus (CHP+) members were accessed through IBM’s MOVEit application. It does not give a total number of affected people.
What happened in the Colorado HCPF MOVEit incident?
HCPF oversees Health First Colorado, Colorado’s Medicaid program, CHP+, and other qualifying health programs. IBM, a vendor contracted with HCPF, used MOVEit Transfer to move HCPF files in the normal course of business. HCPF said its own systems and State of Colorado systems were not affected by the MOVEit software issue; the files identified in its investigation were on IBM’s MOVEit application.
According to HCPF’s notice, an unauthorized actor accessed certain files on or about May 28, 2023. Progress Software discovered a problem affecting MOVEit Transfer on May 31 and publicly announced it as a cybersecurity incident. HCPF says IBM notified the department, it began investigating, and the investigation identified the affected files on June 13. The individual notice is dated August 11, 2023. Read HCPF’s notice filed with Delaware.
Whose information may have been involved?
The notice identifies certain Health First Colorado and CHP+ members as potentially affected, but it does not establish an overall count. It says HCPF began notifying approximately 324 Delaware residents on or about August 11, 2023; that is a Delaware-specific figure, not a statewide or total count.
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The information varied from person to person. Possible data elements listed in the notice and attached consumer letter include:
- Name, date of birth, home address, and other contact information
- Social Security number and Medicaid or Medicare ID number
- Health insurance information and demographic or income information
- Clinical or medical information, which could include a diagnosis or condition, lab results, medication, or treatment details
These are possible categories, not a statement that every person’s file contained every item. HCPF’s notice describes files as accessed; it does not establish that the information was misused.
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Why the “4 million” figure is not supported for this incident
The reviewed HCPF notice does not report that four million people were affected. An approximately 4.2 million figure appears in a separate Reventics litigation matter, where a court-document search result describes the size of that case’s settlement class. It concerns a different matter and should not be attributed to HCPF’s MOVEit incident. View the Reventics court filing.
No population-wide total for the HCPF incident is established by the sources cited here. The notice reviewed here may not be the last word on any later supplemental count, so the responsible conclusion is that the total remains unresolved—not that the impact was four million.
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What could people who received a notice do?
HCPF’s 2023 notice offered notified individuals two years of Experian credit monitoring and identity restoration. The enrollment deadline was November 30, 2023, so this was a historical offer, not a current opportunity to enroll through that notice. It also advised recipients to monitor accounts and credit reports.
If you received a letter, use its contact details to verify whether it concerns you and review the specific information it says may have been involved. For ongoing account safety, monitor financial and health-related accounts for unfamiliar activity and review credit reports for unexpected accounts or inquiries. The notice’s possible data categories do not establish which fields, if any, were present in a particular person’s records.
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What Colorado’s notification guidance says
Colorado Attorney General guidance says covered entities must notify affected Colorado residents without unreasonable delay and within 30 days after determining a breach occurred. It also says the Attorney General must be notified when 500 or more Colorado residents are reasonably believed to be affected. For organizations using third-party service providers, the guidance describes a requirement for reasonable security procedures appropriate to the disclosed information unless the organization agrees to provide the security itself. See the Colorado Attorney General’s data-protection guidance.
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1Scan for outdated or missing drivers - takes under a minute2Clear out junk files and repair common Windows errors3Fix the driver behind crashes, sound loss and screen glitchesThis general guidance does not establish legal fault or a violation by HCPF. The incident notice establishes HCPF’s account of vendor-held files being accessed; it does not, by itself, resolve questions of legal compliance.
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