To be a breach - there has to be damages - risk to reputational and financial harm etc...thus a risk analysis would have to be performed, (before reporting it as a breach - according to the regulations). however, as you indicated many health care pro...
The question is - is this PHI? You said a person posted a photo of her and her patient. If the healthcare provider's photo indicates what that healthcare provider does, i.e., the provider's specialty, then it may be PHI. Remember - to be regulate...