Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing AZ-20230817-blue-cross-blue-shield-of-arizonaHHS OCR Breach Register, Arizona

Breach filing

Archived

Blue Cross Blue Shield of Arizona: 47,485 individuals, Aug 2023.

Blue Cross Blue Shield of Arizona reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 17 August 2023. The filing records the organisation as a health plan in Arizona and lists 47,485 individuals affected, which makes it the 26th largest of the 164 Arizona filings on the register and the 211th largest of the 746 filings submitted nationally in 2023. Among the 17 Arizona filings made in 2023 it ranks 3rd.

Individuals affected

47,485

As reported to HHS

Modelled cost (IBM 2025)

$7.60M

Method shown, not disclosed

Rank in AZ

26th

of 164 Arizona filings

Rank in 2023

211th

of 746 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
47,485
Breach submission date
17 August 2023
Submission year
2023
Type of breach
Hacking/IT Incident
Location of breached information
Network Server
Business associate present
Yes
Portal status
listed in the HHS OCR breach portal archive
Rank in Arizona by size
26th of 164
Rank in 2023 nationally
211th of 746
Arizona median filing
3,146 individuals
Register id (derived)
AZ-20230817-blue-cross-blue-shield-of-arizona

Section F.2 / In context

Where this filing sits in Arizona and in 2023

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 82% of all filings submitted in 2023. 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 47,485 individuals the breach is 15 times the Arizona median filing of 3,146 and 12 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 47,485 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 $7.60M; the 2026 edition's $192 gives $9.12M. Both are modelled estimates with the method shown, not costs disclosed by Blue Cross Blue Shield of Arizona. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.4 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.

Blue Cross Blue Shield of Arizona, the covered entity (CE), reported that a vendor of its business associate (BA) was the subject of a cybersecurity incident that compromised the protected health information (PHI) of 47,485 individuals. The PHI involved included names, dates of birth, addresses, Social Security numbers, and financial information. The CE notified HHS; the BA notified affected individuals and the media. In its mitigation efforts, the BA and vendor implemented new technical safeguards, provided affected individuals with free credit monitoring, and revised its policies and procedures. The CE implemented new security measures to prevent similar attacks from occurring in the future.

Section F.5 / Modelled cost

47,485 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$7.60M

47,485 x $160

IBM 2026 customer PII, $192 per record

$9.12M

47,485 x $192

Method: individuals affected, as reported by Blue Cross Blue Shield of Arizona 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 2023, topped up from other years where 2023 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Cardiovascular Consultants Ltd.Healthcare Provider484,0001 Dec 2023
Phoenician Medical Center, IncHealthcare Provider163,5325 Jul 2023
Mt. Graham Regional Medical CenterHealthcare Provider35,68829 Sep 2023
Arizona Health Advantage dba Arizona Priority Care and AZPC ClinicsHealthcare Provider10,9781 Feb 2023

Index / Companion schedules

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 1555.

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.