Breach filing
ArchivedArizona Complete Health: 34,978 individuals, Mar 2021.
Arizona Complete Health reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 2 March 2021. The filing records the organisation as a health plan in Arizona and lists 34,978 individuals affected, which makes it the 34th largest of the 164 Arizona filings on the register and the 171st largest of the 715 filings submitted nationally in 2021. Among the 15 Arizona filings made in 2021 it ranks 7th.
Individuals affected
34,978
As reported to HHS
Modelled cost (IBM 2025)
$5.60M
Method shown, not disclosed
Rank in AZ
34th
of 164 Arizona filings
Rank in 2021
171st
of 715 filings nationally
Section F.1 / The filing
As posted by HHS OCR
Every value below is the portal's own field for this filing, plus its rank within the register.
- Covered entity type
- Health Plan
- Individuals affected
- 34,978
- Breach submission date
- 2 March 2021
- Submission year
- 2021
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Arizona (AZ)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Arizona by size
- 34th of 164
- Rank in 2021 nationally
- 171st of 715
- Arizona median filing
- 3,146 individuals
- Register id (derived)
- AZ-20210302-arizona-complete-health
Section F.2 / In context
Where this filing sits in Arizona and in 2021
OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server. Hacking/IT Incident is the type recorded on 94 of the 164 Arizona filings (57%) and on 76% of all filings submitted in 2021. Network Server appears on 43% of Arizona filings.
A business associate is recorded as present on the filing, as it is on 21% of Arizona filings. At 34,978 individuals the breach is 11 times the Arizona median filing of 3,146 and 8.7 times the national median of 4,000 across all 7,884 filings. It sits in the 10,000 to 99,999 band, which holds 1,938 filings.
As of 28 August 2026 the case is listed in the HHS OCR breach portal archive. OCR's closing summary of the case is reproduced in full below.
Arizona's breach notification statute (A.R.S. 18-551, 18-552) requires notice to affected residents within 45 days after determining a breach occurred. Its attorney general threshold: more than 1,000 Arizona residents (AG and Dept. of Homeland Security). The HIPAA Breach Notification Rule ran alongside it: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery, which is the clock that put this filing on the portal.
Multiplying 34,978 individuals by IBM's $160 customer-PII cost per record (Cost of a Data Breach 2025, the figure the site's calculator uses) gives a modelled $5.60M; the 2026 edition's $192 gives $6.72M. Both are modelled estimates with the method shown, not costs disclosed by Arizona Complete Health. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.0 times the sector average.
Section F.3 / OCR closing summary
The portal's archived description, in full
Written by the Office for Civil Rights when the case was closed and reproduced verbatim from the HHS export.
The covered entity (CE), Arizona Complete Health, reported that its business associate experienced a cyber-attack that affected the electronic protected health information (ePHI) of 34,978 individuals. The ePHI involved included names, health insurance information, addresses, dates of birth, Social Security numbers, diagnoses, and medications prescribed. The CE notified HHS, affected individuals, the media, and provided substitute notice. Following the breach, the CE provided complimentary identity protection services.
Section F.5 / Modelled cost
34,978 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$5.60M
34,978 x $160
IBM 2026 customer PII, $192 per record
$6.72M
34,978 x $192
Method: individuals affected, as reported by Arizona Complete Health to HHS, multiplied by IBM's customer-PII cost per record (Cost of a Data Breach 2025 Figure 6 and the 2026 edition). No cost has been disclosed by the entity for this filing; the figure is a planning estimate, not a fact about the breach. IBM's per-record figures come from mid-volume breaches and IBM cautions against applying them to breaches involving millions of records; the site's per-record page explains where the multiplication holds and where it breaks down.
Context: IBM's average cost of a healthcare breach is $6.64M in the 2026 report ($7.42M in 2025); the global average across all sectors was $4.44M in 2025.
Cost per record: method and limits / Healthcare breach cost, IBM 2026
Section F.6 / Notification clock
Arizona statute and the HIPAA rule
State notification statute
Arizona: A.R.S. 18-551, 18-552
- Notice to individuals
- Within 45 days after determining a breach occurred
- Attorney general threshold
- More than 1,000 Arizona residents (AG and Dept. of Homeland Security) (Within the same 45-day window)
- Private right of action
- No: Only the Arizona Attorney General may enforce
- Penalty
- Up to $10,000 per affected individual, capped at $500,000 per breach, under the Consumer Fraud Act
The HIPAA Breach Notification Rule runs alongside the state statute: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.
Section F.7 / Peer filings
Arizona filings closest in size
Neighbours by size rank among Arizona filings in 2021, topped up from other years where 2021 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Good Health Medical dba MY DR NOW | Healthcare Provider | 36,781 | 17 May 2021 | |||
| Queen Creek Medical Center d/b/a Desert Wells Family Medicine | Healthcare Provider | 35,000 | 30 Aug 2021 | |||
| Asarco Health, Dental, Vision, Flexible Spending, Non-Union Employee Benefits, and Retiree Medical Plans | Health Plan | 28,000 | 3 Sep 2021 | |||
| A New Leaf, Inc. | Healthcare Provider | 10,438 | 30 Dec 2021 |
Index / Companion schedules
13 HHS breach register
→Hub: every filing, by state, year and entity.
04 Biggest breaches
→Mega-breaches with primary-source cost figures.
Industry / Healthcare
→IBM 2026: $6.64M average, 13 years at #1.
Regulation / HIPAA penalties
→OCR enforcement tiers and the 60-day rule.
11 50-state laws
→Deadline, AG threshold and penalties per state.
Cost / Per record
→Where the per-record model is reliable.
Provenance
Source: U.S. Department of Health and Human Services, Office for Civil Rights, Breach Portal (breaches affecting 500 or more individuals), retrieved 2026-08-28. Public domain. Individuals affected and dates as reported by the covered entity.
Portal: ocrportal.hhs.gov breach report. Statutory basis: HITECH Act section 13402(e)(4): the Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals. Breaches affecting fewer than 500 individuals are reported to OCR annually and are not posted, so they are not on this register. Status wording follows the portal's two tabs ("Cases Currently Under Investigation" and "Archive") as of 28 August 2026; a filing moves to the archive when OCR closes the case. Modelled costs on this site are a method applied to the reported count, using IBM Cost of a Data Breach per-record figures, and are never a cost disclosed by the entity. This row: hhs-breach-archive__2026-08-28.csv, export row 3363.
Corrections: if you represent a listed entity and the portal row has been amended, email [email protected] with the portal entry and we will re-pull the export.