Immanuel Pathways

NOTICE OF DATA PRIVACY INCIDENT


PACE Nebraska, doing business in Nebraska as Immanuel Pathways, and PACE Iowa, doing business in Iowa as Immanuel Pathways, (each, individually, “Pathways”), provide notice of a recent incident at a third-party vendor, PeakTPA, that may affect the security of information for current and former participants enrolled in the Program of All-Inclusive Care for the Elderly (“PACE”). PeakTPA is a third-party administrator of certain PACE services and participant information was shared by Pathways to assist with this program. The confidentiality, privacy, and security of participant information is among one of Pathways’ highest priorities, and Pathways takes this incident very seriously.  Please know that to date, Pathways has not received any reports of actual or attempted misuse of participant information.

What Happened?  On January 23, 2021, PeakTPA notified Pathways that on December 31, 2020, PeakTPA became aware of unusual activity involving their computers which resulted in the unauthorized access to certain participant information.  Upon receiving notice of this incident, Pathways launched an investigation to find out what impact it may have on PACE participant information and to who that information belonged. During Pathways’ investigation, PeakTPA reported that certain information of current or former PACE participants may have been accessed on or about December 29 and December 31, 2020.  This incident did not involve internal Pathways’ systems.

What Information Was Involved? On January 27, 2021, Pathways received additional information from PeakTPA which allowed Pathways to determine which current and former PACE participant information was involved. Pathways’ investigation confirmed that certain current and former participant names, dates of birth, address, Medicare identification numbers, prescription information, and/or health insurance claim information was involved.  In some cases, current and former participant Social Security numbers were also involved. 

What We are Doing. PeakTPA is directly notifying the potentially impacted participants on behalf of Pathways and as an added precaution, is providing impacted participants with access to complementary credit monitoring and identity protection services.  As part of its ongoing commitment to security of information in its care, Pathways is working to review its existing policies and procedures regarding third-party vendors and is working with PeakTPA to evaluate additional measures and security to protect against this type of incident in the future.  Notice will also be provided to state and federal regulators, as required.

For More Information.  You may have questions about this incident.  If you have any additional questions and are impacted by this incident, please contact PeakTPA's dedicated assistance line at 855-761-0196 between the hours of 8:00 a.m. to 5:30 p.m. central time. You may also write to PeakTPA at 345 Marshall Ave. Suite #101. St Louis, MO 63119. 

What You Can Do. Pathways encourages affected participants to remain vigilant against incidents of identity theft and fraud, to review Explanation of Benefits and account statements, and to monitor credit reports for suspicious activity.  Under U.S. law consumers are entitled to one free credit report annually from each of the three major credit reporting bureaus. If you have further questions regarding your rights in relation to your credit report, please review the information contained in the letter that was mailed to you.  If you are a participant and believe you may be impacted by this incident, you may also call 855-761-0196 for more information. 
Instances of known or suspected identity theft should also be reported to law enforcement and your state Attorney General.  Consumers may further educate themselves regarding identity theft, fraud alerts, credit freezes, and the steps they can take to protect personal information by contacting the consumer reporting bureaus below: