BA Breach & Fines Examples

Patient Data Compromised in Cyberattacks on Sleep Specialists

Two sleep specialists, Persante Health Care in New Jersey and SomnoSleep Consultants in Virginia, have recently disclosed security incidents that exposed patient information.

Persante Health Care Patients Informed About January 2025 Cyberattack

Persante Health Care, a Mount Laurel Township, NJ-based national provider of sleep and balance center management services to hospitals and physician practices, has announced a security incident that was detected on or around January 28, 2025.

Unusual activity was identified within its computer network and, assisted by third-party cybersecurity experts, it was determined that an unauthorized third party accessed its network between January 23 and January 28, 2025. During that time, files containing patient information may have been accessed or acquired. It took more than 8 months to review the affected files to determine whether patient data had been exposed. On October 3, 2025, the data review confirmed that personal and protected health information was involved.

The exposed data varied from individual to individual and may have included names in combination with one or more of the following: date of birth, Social Security number, driver’s license number, state identification number, passport number, government identification number, taxpayer identification number, date(s) of service, physician or facility name, patient account number, medical record number, financial account information, payment card number, medical device identifier(s), and/or biometric identifier(s).

The Federal Bureau of Investigation was informed about the cyberattack, and Persante Health Care is assisting with the investigation. Additional measures have been implemented to reduce the risk of similar incidents in the future, and the affected individuals were notified by mail on November 26, 2025. The number of affected individuals has yet to be publicly disclosed.

SomnoSleep Consultants’ Patients Affected by Business Associate Data Breach

Patients of Annadale, VA-based SomnoSleep Consultants have been notified about a security incident at a third-party billing vendor, Avosina Healthcare Solutions. The vendor detected unauthorized access to its network on July 29, 2025, in what appears to have been a ransomware attack. Avosina said it was able to restore its services from backups; therefore, no ransom was paid. The FBI was notified, and third-party cybersecurity experts were engaged to determine the nature and scope of the incident and implement additional security measures to protect against further attacks.

The investigation confirmed that some documents were exfiltrated from its network. The analysis of those files confirmed that they contained patients’ names, addresses, medical information, and health insurance information. SomnoSleep said there was no unauthorized access to any files part of its electronic medical record system.

Avosina notified SomnoSleep about the attack on September 29, 2025, and on November 17, 2025, SomnoSleep provided additional information on the affected patients and delegated the responsibility for sending notification letters to its business associate. SomnoSleep said that no evidence has been found to indicate that any of the impacted patient data has been misused.

Avosina confirmed to SomnoSleep that steps have been taken to correct the vulnerability that was exploited by the threat actor, and other security measures have been implemented to protect against any further unauthorized network access. Internal data management protocols have also been reviewed.

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Geisinger Health & Nuance Communications Data Breach Litigation Settled for $5 Million

The Danville, Pennsylvania-based healthcare provider Geisinger Health and its former IT vendor Nuance Communications, Inc., have agreed to a $5 million settlement to resolve class action litigation over a 2023 insider data breach involving a former Nuance Communications employee.

On or around November 29, 2023, Geisinger Health learned that a former Nuance Communications employee, Andre J. Burk (also known as Max Vance), accessed the sensitive data of Geisinger Health patients two days after he was terminated by Nuance Communications. The data had been provided to Nuance Communications in connection with the services the IT company was contracted to provide. The breach was detected by Geisinger Health, rather than Nuance Communications, and it alerted its IT vendor about the breach.

Under HIPAA, business associates of HIPAA-regulated entities must comply with the HIPAA Security Rule, one of the requirements of which is to ensure that access rights are immediately revoked when employees are terminated. When notified about the unauthorized access, Nuance Communications terminated the former employee’s access rights and launched an investigation, which revealed that the former employee had potentially obtained the protected health information of more than 1.2 million Geisinger Health patients, including names, dates of birth, Social Security numbers, medical information, and health insurance information.

The affected individuals started to be notified about the data breach on June 24, 2024. The delay in notification was at the request of law enforcement. The HHS’ Office for Civil Rights was informed that the protected health information of 1,276,026 individuals was involved. Max Vance is now facing criminal charges over the data theft – one count of obtaining information from a protected computer – and his trial is scheduled for early January 2026.

Several lawsuits were filed against Geisinger Health and Nuance Communications, Inc. in response to the data breach, which were consolidated into a single action in July 2024 – In re: Geisinger Health Data Security Incident Litigation – in the U.S. District Court for the Middle District of Pennsylvania. The consolidated lawsuit alleged that the defendants failed to implement and maintain reasonable and adequate security measures to secure, protect, and safeguard the plaintiffs’ and class members’ personal and protected health information.

The lawsuit alleged that Geisinger Health failed to ensure that its vendors employed reasonable security measures, that Nuance Communications failed to properly monitor systems for intrusions, there was insufficient network segmentation, and a failure to comply with FTC guidelines, the HIPAA Rules, and the defendants did not adhere to industry standard cybersecurity measures. The lawsuit asserted claims of negligence, negligence per se, breach of implied contract, breach of third-party beneficiary contract, unjust enrichment, and declaratory judgment and injunctive relief against both defendants, and breach of fiduciary duty against defendant Geisinger Health.

The defendants disagree with the claims in the lawsuit; however, they chose to settle with no admission of wrongdoing to avoid the expense and uncertainty of a trial and related appeals. The settlement received preliminary approval from District Court Judge Matthew W. Brann on November 18, 2025. Under the terms of the settlement, the defendants will establish a $5,000,000 settlement fund, from which attorneys’ fees and expenses, service awards, and settlement administration costs will be deducted. The remainder of the funds will be used to pay benefits to the class members.

The class consists of 1,308,363 class members who may choose to receive a one-year membership to a credit monitoring and identity theft protection service. In addition, a claim may be submitted for reimbursement of documented, unreimbursed out-of-pocket losses due to the data breach up to $5,000 per class member. Alternatively, instead of a claim for reimbursement of losses, class members may choose to receive a pro rata cash payment. The final approval hearing has been scheduled for March 16, 2026, and claims must be submitted by March 18, 2026.

June 24, 2024: Geisinger: Former Business Associate Employee Unlawfully Accessed PHI of More Than 1.2 Million Patients

More than one million Geisinger patients are being notified that their protected health information has been unlawfully accessed by a former employee of one of its business associates, Nuance Communications.

Nuance Communications provides information technology services to Geisinger, which requires access to systems containing patient information. On November 29, 2023, Geisinger detected unauthorized access to patient data by a former Nuance employee and immediately notified Nuance about the incident. Nuance immediately terminated the former employee’s access and launched an investigation, which confirmed that the former employee accessed patient data two days after they were terminated.

The former employee may have viewed and acquired the data of more than one million Geisinger patients. The data varied from patient to patient and may have included names, addresses, phone numbers, dates of birth, admission/discharge/transfer codes, medical record numbers, facility name abbreviations, and race and gender information. Nuance has confirmed that the employee did not have access to Social Security numbers, financial information, or claims/insurance information.

The Department of Justice can pursue criminal charges for HIPAA violations under the Social Security Act when individuals knowingly violate HIPAA. When an employee of a HIPAA-covered entity or business associate has their employment terminated, HIPAA still applies. The penalties for accessing and obtaining protected health information are severe and can include a hefty fine and jail time. A tier 1 violation carries a maximum penalty of up to a year in jail, a tier 2 violation carries a jail term of up to 5 years, and a sentence of up to 10 years in jail is possible for a tier 3 violation – obtaining PHI for personal gain or with malicious intent. Geisinger has confirmed that the unauthorized access was reported to law enforcement and the former Nuance employee has been arrested and is facing federal criminal charges.

Due to the high risk of unauthorized access to patient data by former employees, HIPAA-covered entities and their business associates are required to develop and implement procedures for terminating access to electronic protected health information when employment comes to an end under the workforce security standard of the HIPAA Security Rule – 45 CFR § 164.308 (3)(ii)(C). This incident clearly shows why it is vital to revoke access immediately upon termination of employment. The HHS’ Office for Civil Rights has taken action over violations of this Security Rule provision in 2020 (City of New Haven) and 2018 (Pagosa Springs Medical Center).

The Risant Health-owned health system has confirmed that Nuance Communications is mailing notifications to the affected individuals. Patients have been advised to review the statements they receive from their health plans and contact their health insurer if any services appear on their statements that they have not received. A helpline has been set up for individuals requiring further information about the breach – 855-575-8722. The helpline is manned from 9 a.m. to 9 p.m. ET Monday to Friday. Callers should quote engagement number B124651.

The breach was reported to the HHS’ Office for Civil Rights as affecting 1,276,026 individuals.

This article has been updated to state the number of people affected by the breach, as that information was unavailable at the time of the initial post.

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EHR Vendor Identifies Business Associate Data Breach

Data breaches have recently been announced by the EHR vendor CareTracker (Amazing Charts) and the Wisconsin health system, Marshfield Clinic.

CareTracker (Amazing Charts)

CareTracker Inc., doing business as Amazing Charts, an electronic health record and practice management platform provider, has been affected by a security incident at one of its vendors. On June 19, 2025, Amazing Charts identified unusual activity within a system managed by a third-party vendor. Immediate action was taken to secure the vendor’s environment, and an investigation was launched to determine the nature and scope of the activity.

The investigation confirmed unauthorized access to the service provider’s network between June 15, 2025, and June 19, 2025. Files were then reviewed to determine the individuals affected and the types of data involved. Due to the complexity of the data review, that process has only recently been completed.

Data potentially compromised in the incident included names in combination with one or more of the following: diagnoses, treatment information, physician names, medical record numbers, and health insurance information. Notification letters have recently been mailed to the affected individuals, and complimentary credit monitoring services have been offered for 12 months. At the time of notification, no misuse of the affected information had been identified.

Marshfield Clinic Health System

Marshfield Clinic Health System, an integrated health system serving Wisconsin and Michigan’s Upper Peninsula, identified unauthorized access to certain employee email accounts on or around August 27, 2025. The forensic investigation confirmed that an unauthorized third party had access to the accounts from August 26 to August 27, 2025, and potentially accessed or copied emails containing patient information. The types of information compromised in the incident varied from individual to individual and may have included names, medical record numbers, health insurance information, diagnosis, and treatment information.

The affected individuals are being notified by mail and have been offered complimentary credit monitoring and identity theft protection services. The incident is not yet shown on the HHS’ Office for Civil Rights website, so it is currently unclear how many individuals have been affected.

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Wakefield & Associates Announces Breach of Client Data

Wakefield & Associates, a Knoxville, Tennessee-based vendor that offers revenue cycle & collections services to healthcare providers, has recently announced a security incident that was identified on or around January 17, 2025.

Wakefield & Associates explained in a website data breach notice that suspicious activity was identified within its computer systems, and the forensic investigation confirmed unauthorized access to files containing the protected health information of patients of its healthcare clients. Some of those files were exfiltrated from its network on or before January 17, 2025. The breach notice issued to the Maine Attorney General states that initial access occurred on January 14, 2025.

Following an extensive review of the exposed data, Wakefield & Associates determined on September 24, 2025, that some of the exposed files contained protected health information that was provided to the company by its healthcare clients. The information potentially compromised in the incident was mostly limited to names and collection account information, although for some individuals, it included their Social Security number, financial account information, driver’s license number/state identification number, and/or health information.

Wakefield & Associates is issuing notification letters on behalf of its affected clients and is offering the affected individuals complimentary credit monitoring and identity theft protection services. Existing security policies and procedures have been reviewed, and additional safeguards implemented to prevent similar incidents in the future.

The breach notice does not state the nature of the cyberattack, but this appears to have been a ransomware attack by the Akira threat group. Akira claimed in a February 11, 2025, listing on its dark web data leak site that it stole 13 GB of data in the attack, including patient and employee information.

Wakefield & Associates said law enforcement was notified, and the data security incident has been reported to regulators. The HHS’ Office for Civil Rights (OCR) breach portal has not been updated since late September due to the government shutdown, so it is currently unclear how many individuals have been affected. The Montana Attorney General was informed that 26,624 state residents were affected, and the Maine Attorney General was notified that 41 Maine residents were affected. Northern Montana Health Care has confirmed that it was one of the affected clients.

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Conduent Anticipates Data Breach Cost to Rise to $50M by Q1, 2026

In its first-quarter earnings report, Conduent said it did not experience any material impacts to its operating environment or costs from the January 2025 cyberattack itself; however, it did incur $25 million in non-recurring expenses from direct response costs. Those losses have continued to increase, with a further $9 million added to that total for breach notifications through the end of September, according to its third-quarter earnings report.

Conduent also anticipates incurring a further $16 million in costs related to breach notifications by the first quarter of 2026, but said it holds a cyber insurance policy and anticipates that any additional notification costs will be covered by the insurance policy.

Further costs may be incurred due to the impacted data, reputational harm, litigation, and regulatory actions, which could impact the company’s financial position. As reported below, several lawsuits have already been filed in response to the data breach, and Conduent is certain to be investigated by the HHS’ Office for Civil Rights and state attorneys general. Regulatory fines may be imposed if Conduent is found to have violated state or federal regulations.

November 7, 2025: Lawsuits Mount Over 10.5 Million-Record Conduent Data Breach

A data breach affecting more than 10.5 million individuals was certain to trigger a barrage of lawsuits, and litigation has been swift, with at least 9 class action lawsuits already filed in response to the Conduent data breach in New Jersey federal court. That total is certain to grow over the coming days and weeks, as many law firms have announced that they have opened investigations regarding potential class action litigation.

The lawsuits make similar claims – that Conduent was negligent by failing to adequately protect its network against unauthorized access and for its alleged failure to provide adequate notifications to the individuals affected by the data breach. The cyberattack was first detected by Conduent in January 2025, three months after hackers first gained access to its network. Conduent first announced the data breach three months later, confirming that sensitive data had been exposed and that the incident affected a substantial number of individuals.

It naturally takes time to investigate any data breach and to determine the number of individuals affected and the types of data involved; however, the lawsuits take issue with the length of that process. It has taken 10 months from when the cyberattack was first detected for the scale of the breach to become clear and for the affected individuals to be notified that their sensitive information has been compromised. Notification letters started to be sent in October 2025, one year after Conduent’s network was first accessed by unauthorized individuals.

In addition to negligence and negligence per se, the lawsuits assert claims such as breach of third-party beneficiary contract and unjust enrichment, and seek a jury trial, compensatory, statutory, and punitive damages, and injunctive relief, requiring the court to order Conduent to implement a range of security measures to ensure sensitive data is adequately protected.

The threat group behind the attack may have been the Safepay ransomware group, which added Conduent to its data leak site in January 2025, although Conduent is not currently listed on the Safepay data leak blog. That often means that a ransom has been paid or the stolen data has been sold, although ransomware groups have been known to fabricate claims.

Class action lawsuits are mounting, but Conduent is also likely to face regulatory scrutiny over the data breach. States are likely to investigate a data breach of this magnitude to determine whether appropriate cybersecurity measures had been implemented in line with state laws and the HIPAA Security Rule. Questions are likely to be asked about how the hackers were able to gain access to such a large amount of sensitive data.

Conduent will also face scrutiny from the HHS’ Office for Civil Rights, which will seek to establish whether the data breach was the result of HIPAA compliance failures. While OCR HIPAA compliance investigations often take many months or years, OCR has indicated it is prioritizing high-impact incidents, as it did with the cyberattack on Change Healthcare, which affected north of 190 million individuals. There is, at this stage, no indication that Conduent has violated any regulations at the federal or state level.

October 28, 2025: More Than 10.5 Million Patients Affected by Conduent Business Solutions Data Breach

A data breach at a business associate of several HIPAA-covered entities and government agencies has resulted in the exposure and potential theft of the protected health information of more than 10.5 million patients. The Conduent Business Solutions data breach is the largest healthcare data breach to be announced so far this year, affecting almost twice as many individuals as the second-largest data breach, which was reported earlier this year by Yale New Haven Health. It also ranks as the 8th largest healthcare data breach in history.

Conduent Business Solutions provides a range of back-office services, including printing, mailing, document processing, payment integrity services, and other support services to government agencies and healthcare organizations. It is currently unknown how many HIPAA-regulated entities have been affected by the data breach.

Blue Cross and Blue Shield of Montana recently announced that it had been affected and that notification letters are being mailed to 462,000 individuals. Blue Cross and Blue Shield of Texas has announced that approximately 310,000 UT Select and UT Care plan members have been affected. The incident is also known to have affected Humana customers and Premera Blue Cross members, although it is unclear how many. Conduent provides services to government agencies such as the Wisconsin Department of Children and Families and Oklahoma Human Services (OHS), which experienced temporary disruption to some of their services due to the outage in January, although OHS was informed that it did not have sensitive data exposed in the incident.

State regulators have been informed that 10,515,849 patients have been affected, including more than 4 million individuals in Texas. It is unclear if any non-healthcare clients had data compromised in the incident. The Conduent Business Solutions data breach was reported to the U.S. Securities and Exchange Commission (SEC) in April. In the SEC filing, Conduent explained that a threat actor gained access to a limited portion of its network IT environment and obtained the data of “a significant number” of people. The incident is not yet shown on the HHS’ Office for Civil Rights (OCR) breach portal, which has not been updated by OCR since September 24, 2025, due to the government shutdown.

The intrusion was detected on January 13, 2025. Assisted by third-party digital forensics experts, Conduent determined that initial access occurred on October 21, 2024, with the threat actor maintaining access for almost three months until Conduent secured its network on January 13, 2025. Conduent said it restored access to the affected systems within days, and in some cases, within hours, and the incident did not have any material impact on its operations.

The investigation confirmed that the threat actor exfiltrated files associated with some of its clients. Due to the complexity of the data involved, it has taken several months to complete the file review and determine the individuals affected and the types of data involved. Individual notifications are now being mailed to the affected individuals.

Information compromised in the incident varies from company to company and individual to individual, potentially involving names, dates of birth, Social Security numbers, treatment information, and claims information. Based on the notice provided to the California Attorney General, complimentary credit monitoring and identity theft protection services do not appear to have been offered.

While the total cost of the cyberattack is not yet known, Conduent said in its May 2025 first-quarter earnings report that it incurred $25 million in direct costs related to the breach response. A cyber insurance policy is held, which will cover a proportion of the cost.

This post will be updated when further information is released.

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Business Associate Data Breach Affects 462,000 Blue Cross Blue Shield of Montana Members

Approximately 462,000 current and former customers of Blue Cross Blue Shield of Montana (BCBSMT) have been affected by a cyberattack on its New Jersey-based business associate, Conduent Business Services. Conduent Business Services provides BCBSMT with payment, document processing, and other back office services, which require access to BCBSMT members’ protected health information. On January 13, 2025, Conduent Business Services identified a security incident that caused operational disruption – terminology typically used to describe a ransomware attack.

Conduent Business Services was able to restore access to the affected systems and return to normal business operations within a few days. The investigation confirmed unauthorized access to its IT environment commencing on October 21, 2024, and lasting for almost three months. During that time, files were exfiltrated from its network. On April 9, 2025, Conduent Business Services disclosed the cyberattack in a filing with the U.S. Securities and Exchange Commission (SEC). At the time, it was unclear exactly how many individuals had been affected.

On October 8, 2025, Conduent Business Services notified the California Attorney General about the data breach, which reportedly affected approximately 4.3 million individuals. It is unclear how many of the company’s clients were affected by the breach, and if the breach affected any other HIPAA-covered entity clients. The breach is not currently listed on the HHS’ Office for Civil Rights website.

BCBSMT notified the Montana State Auditor’s Office about the data breach in early October, almost one year after the breach was first detected by its business associate. BCBSMT claims to have been notified that it was affected earlier this year and has been conducting its own investigation and reviewing the affected data. The review was not completed until September 23, 2025. The BCBSMT data breach is not listed on the OCR breach portal, although the breach portal has not been updated by OCR since September 24, 2025, due to the government shutdown. The Montana State News Bureau learned about the data breach after submitting a records request. The obtained documents indicate that up to 462,000 Montanans have been affected, and that the compromised information included names, birth dates, Social Security numbers, treatment and diagnosis codes, provider names, and claims amounts.

The Montana Commissioner of Securities and Insurance has launched an investigation to determine if there has been a violation of state data breach notification laws, which require individuals to be notified about a data breach in a timely manner. Breached entities must also notify the Department of Justice about a data breach without unreasonable delay, but there is currently no listing on the DOJ consumer protection website about the data breach. The state auditor is seeking answers to questions about the data breach and has requested a copy of its privacy and security policies. Should BCBSMT be determined to have failed to comply with state laws, financial penalties may be imposed.

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September 2025 Healthcare Data Breach Report

While the figures in our September 2025 data breach report look encouraging, there is a major caveat. Due to the government shutdown, the HHS’ Office for Civil Rights (OCR) has largely stopped adding data breaches to its data breach portal.  The figures for September are therefore likely to increase considerably when the furlough comes to an end, staff return to work, and the backlog of data breach reports is addressed. While we do not generally update our monthly breach reports after publication, we will revise the figures and re-publish this report when the government shutdown comes to an end.

September 2025 Healthcare Data Breach Report

As of October 22, 2025, OCR has added 26 data breaches affecting 500 or more individuals to its data breach portal – the lowest monthly total since December 2018.  While data breaches are down 56% from August’s 64 data breaches, there are likely to be several more breaches added to that total. That said, there has been a downward trend in healthcare data breaches since April, and the year-to-date total from January 1 to September 30 is 469 data breaches, compared to 554 data breaches in the corresponding period in 2024. Even accounting for missing breach reports due to the government shutdown, data breaches are down considerably from last year.

Healthcare data breaches in the past 12 months

Across the 26 September data breaches on the OCR data breach portal, the protected health information of at least 1,294,769 individuals was exposed or impermissibly disclosed, marking the third consecutive month with a fall in the number of affected individuals, and currently down 65.9% from August. That number could increase considerably, but currently, for the year-to-date, 42,216,193 individuals have had their protected health information exposed or impermissibly disclosed. While this year’s total is higher than in the whole of 2019 and 2020, the number of affected individuals is down 85% compared to last year and 75% compared to 2023.

Individuals affected by healthcare data breaches in the past 12 months.

The Biggest Healthcare Data Breaches Announced in September

Currently, 42% of the month’s breaches (11 incidents) involved the exposure or impermissible disclosure of the protected health information of 10,000 or more individuals. All but one of the 11 data breaches were hacking incidents involving unauthorized access to protected health information stored on network servers, with one incident involving a compromised email account. Goshen Medical Center was the worst-affected covered entity, with more than 456,000 patients affected by its hacking incident. One provider that stands out is Sturgis Hospital, which was investigating a cyberattack that occurred in December 2024, when another intrusion was experienced in June 2025.

Name of Covered Entity State Covered Entity Type Individuals Affected Cause of Breach
Goshen Medical Center NC Healthcare Provider 456,385 Network server hacking incident
Medical Associates of Brevard, LLC FL Healthcare Provider 246,711 Network server hacking incident
Doctors Imaging Group FL Healthcare Provider 171,862 Network server hacking incident – Data theft confirmed
Retina Group of Florida FL Healthcare Provider 152,691 Network server hacking incident
Sturgis Hospital MI Health Plan 77,771 Network server hacking incident
Sturgis Hospital MI Healthcare Provider 77,771 Network server hacking incident
PGA Development, Inc. PA Healthcare Provider 23,899 Network server hacking/IT Incident
Teamsters Union 25 Health Services & Insurance Plan MA Health Plan 19,231 Network server hacking incident
Health & Palliative Services of the Treasure Coast, Inc d/b/a Treasure Coast Hospice  (“Treasure Health ”) FL Healthcare Provider 13,234 Email account breach
People Encouraging People MD Healthcare Provider 13,083 Ransomware attack – Data theft confirmed

The HIPAA Breach Notification Rule requires HIPAA-covered entities to report data breaches to OCR and issue notifications within 60 days of the discovery of a data breach; however, if the total number of affected individuals is not known at that point, an estimate should be provided to OCR. Many regulated entities submit a breach report using a placeholder figure of 500 or 501 affected individuals, then provide an updated total when the file review is concluded. Four data breaches were reported in September using 500 or 501 totals indicative of a placeholder. These data breaches could affect considerably more individuals than the initial breach report suggests.

Name of Covered Entity State Covered Entity Type Individuals Affected Type of Breach
Cookeville Regional Medical Center TN Healthcare Provider 500 Hacking/IT Incident
Hampton Regional Medical Center SC Healthcare Provider 501 Hacking/IT Incident
Coos County Family Health Services NH Healthcare Provider 501 Hacking/IT Incident
La Perouse, LLC NV Business Associate 501 Hacking/IT Incident

Causes of September 2025 Healthcare Data Breaches

Out of the 23 large healthcare data breaches added to the OCR breach portal in September, 23 (88.5%) were reported as hacking/IT incidents, involving unauthorized access to the protected health information of 1,279,139 individuals, which is 98.8% of the total individuals affected by data breaches in September. The average number of individuals affected by these incidents was 55,615 (median: 6,243 individuals).

Causes of September 2025 healthcare data breaches

The exact nature of the hacking incidents, such as whether ransomware was used to encrypt files, if a ransom demand was received, or even if data was stolen, is often not disclosed. This trend has been growing for several years and is not confined to the healthcare industry. The Identity Theft Resource Center (ITRC) has reported that this trend is evident across many industry sectors.

The remaining three data breaches were unauthorized/disclosure incidents, affecting 15,630 individuals. On average, 5,210 individuals were affected (median: 1,700 individuals). Based on the available data, no loss, theft, or improper disposal incidents were reported to OCR in September. There have been no loss/theft incidents reported since March 2025, and the last reported improper disposal incident was in May 2025.

Location of breaches protected health information in September 2025 healthcare data breaches

Where Did the Data Breaches Occur?

September 2025 healthcare data breaches by regulated entity type

September 2025: individuals affected by healthcare data breaches by regulated entity type

Geographical Distribution of Healthcare Data Breaches in September

Florida and North Carolina were the worst-affected states, with four data breaches affecting 500 or more individuals reported by entities based in those states, and both states top the list in terms of the number of affected individuals, with 584,498 and 465,721 individuals affected, respectively.

State Breaches
Florida & North Carolina 4
Michigan, Pennsylvania & Tennessee 2
Louisiana, Massachusetts, Maryland, Minnesota, Missouri, New Hampshire, Nevada, Oregon, South Carolina, Texas, Virginia, and Washington 1

The table below shows the number of individuals affected by healthcare data breaches based on the state where the regulated entity is based, not necessarily where the affected individuals reside.

State Individuals Affected
Florida 584,498
North Carolina 465,721
Michigan 155,542
Pennsylvania 26,150
Massachusetts 19,231
Maryland 13,083
Missouri 11,538
Louisiana 6,243
Minnesota 3,572
Tennessee 2,957
Oregon 1,700
Texas 1,236
Washington 1,099
Virginia 696
New Hampshire 501
Nevada 501
South Carolina 501

HIPAA Enforcement Activity in September 2025

It has been a busy year of HIPAA enforcement for OCR, with 20 enforcement actions involving settlements or civil monetary penalties announced this year, including one enforcement action in September.  OCR agreed to settle alleged violations of the HIPAA Privacy Rule and Breach Notification Rule with Cadia Healthcare facilities, which agreed to pay $182,000 to resolve the alleged violations.

Cadia Healthcare is a group of five rehabilitation, skilled nursing, and long-term care providers in Delaware. An employee had posted success stories about its patients to its social media channel; however, it had not obtained valid HIPAA authorizations for that purpose, and therefore, the use of PHI in the stories was an impermissible disclosure of PHI. After being notified by OCR, Cadia found that 150 patients had PHI posted online without valid authorizations, deleted the posts, and shut down the success story program; however, notification letters about the HIPAA breach were not issued.  The corrective action plan requires policies and procedures to be revised, training to be provided to staff members, and notification letters to be issued.

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Florida Medication Management Provider Discloses 150K-record Data Breach

Outcomes One, a Florida-based business associate of health plans, has disclosed a phishing incident that has affected almost 150,000 individuals. Emergency Responders Health Center in Idaho has experienced an email breach affecting more than 1,500 individuals.

Outcomes One, Inc., Florida

Outcomes One, Inc., a Florida-based provider of medication therapy management and medication adherence technology solutions to health plans, is notifying 149,094 individuals about a recent email security incident. An employee identified unusual activity in his Outcomes One email account on July 1, 2025, and reported it to the security team. The email account was immediately secured, and an investigation was launched to determine the cause of the activity. The investigation confirmed that the breach was limited to a single employee email account, which had been accessed by an unauthorized third party following a response to a phishing email. Outcomes One said the attack was identified and remediated within an hour.

The account was reviewed and found to contain names in combination with one or more of the following: demographic information, health insurance information, medication information, and medical provider names. The breach notice provided to the California Attorney General indicates the affected individuals had Aetna Health Insurance plans. Outcomes One has provided additional training for the workforce to help with phishing email identification, and additional safeguards have been implemented to reduce the risk of similar breaches in the future.

Emergency Responders Health Center

Emergency Responders Health Center in Boise, Idaho (EHRC), has recently disclosed an email security incident. Unusual activity was identified in an employee’s email account on April 11, 2025. The account was secured, and an investigation was launched to determine the nature and scope of the activity. Assisted by third-party cybersecurity experts, EHRC determined that several email accounts had been accessed by an unauthorized third party. All email accounts have now been secured.

EHRC published a substitute breach notice on its website on July 23, 2025; however, at the time, the investigation and review of the affected accounts were ongoing, so it was not possible to state how many individuals had been affected or the types of information involved. The list of affected individuals was finalized on September 16, 2025, when it was confirmed that a total of 1,528 individuals had been affected, including 526 residents of Washington state. The exposed information included names, dates of birth, driver’s license numbers, Social Security Numbers, medical information, and health insurance information.

Notification letters started to be mailed to the affected individuals on September 26, 2025. To date, EHRC has not identified any misuse of the impacted data, but as a precaution, has offered the affected individuals a complimentary 12-month membership to a credit monitoring and identity theft protection service. EHRC said several steps have been taken to prevent similar breaches in the future. Staff members have received additional security training, user credentials have been changed, and monitoring has been enhanced.

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Medusind to Pay $5 Million to Settle Data Breach Litigation

Medusind has agreed to pay $5,000,000 to settle a consolidated class action lawsuit over a 2023 data breach. Medusind is a revenue cycle management and practice management software vendor based in Florida. On or around December 29, 2023, the firm identified unauthorized access to its computer systems and found evidence to suggest that files had been exfiltrated from its network. The file review confirmed that more than 701,000 individuals had protected health information exposed in the incident, including names, contact information, health insurance information, medical histories, driver’s license numbers, passport numbers, and Social Security numbers. Notification letters were mailed to the affected individuals more than a year after the intrusion was detected.

Victims of the breach took legal action against Medusind, claiming negligence for failing to implement reasonable and appropriate safeguards to protect individuals’ personal and protected health information. Eight separate complaints were filed in response to the data breach. Since they had overlapping claims, they were consolidated into a single action in the United States District Court for the Southern District of Florida – Ashley Owings v. Medusind, Inc. Medusind denies any fault or liability and disagrees with all claims and contentions in the lawsuit. Following mediation on June 10, 2025, all parties agreed to settle the lawsuit, with no admission of wrongdoing by Medusind.

The settlement agreement includes cash benefits for class members, credit monitoring services, statutory awards for the California subclass, and injunctive relief. Medusind will establish a $5 million settlement fund from which the attorneys’ fees and expenses, settlement administration costs, class representative awards for each of the nine named plaintiffs, credit monitoring costs, and cash payments will be paid.

Two cash payments have been offered. Class members may either submit a claim for documented, unreimbursed losses related to the data breach up to a maximum of $5,000. Alternatively, a claim may be submitted for a pro rata cash payment, which is estimated to be around $100 per class member. Cash payments will be paid pro rata after legal costs, expenses, and credit monitoring costs have been deducted from the settlement fund. California residents may claim an additional statutory award, estimated to be $100. All class members are entitled to claim two years of complimentary credit monitoring services.

In addition to the $5,000,000 settlement, Medusind has agreed to implement additional security measures. Prior to receiving final approval, Medusind will provide class counsel with a written attestation regarding the security measures that have been implemented. Class members wishing to exclude themselves from or object to the settlement have until December 14, 2025, to do so. Claims must be submitted by December 29, 2025, and the final approval hearing has been scheduled for January 12, 2026.

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