Breach filing
ArchivedWalmart Associates Health and Welfare Plan: 85,952 individuals, Oct 2023.
Walmart Associates Health and Welfare Plan reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 4 October 2023. The filing records the organisation as a health plan in Arkansas and lists 85,952 individuals affected, which makes it the 8th largest of the 92 Arkansas filings on the register and the 162nd largest of the 746 filings submitted nationally in 2023. Among the 7 Arkansas filings made in 2023 it ranks 1st.
Individuals affected
85,952
As reported to HHS
Modelled cost (IBM 2025)
$13.8M
Method shown, not disclosed
Rank in AR
8th
of 92 Arkansas filings
Rank in 2023
162nd
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
- 85,952
- Breach submission date
- 4 October 2023
- Submission year
- 2023
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Arkansas (AR)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Arkansas by size
- 8th of 92
- Rank in 2023 nationally
- 162nd of 746
- Arkansas median filing
- 4,800 individuals
- Register id (derived)
- AR-20231004-walmart-associates-health-and-welfare-pl
Section F.2 / In context
Where this filing sits in Arkansas 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 50 of the 92 Arkansas filings (54%) and on 82% of all filings submitted in 2023. Network Server appears on 49% of Arkansas filings.
A business associate is recorded as present on the filing, as it is on 28% of Arkansas filings. At 85,952 individuals the breach is 18 times the Arkansas median filing of 4,800 and 21 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.
Arkansas's breach notification statute (Ark. Code Ann. 4-110-101 et seq.) requires notice to affected residents in the most expedient time and manner possible and without unreasonable delay. Its attorney general threshold: more than 1,000 Arkansas residents. 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 85,952 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 $13.8M; the 2026 edition's $192 gives $16.5M. Both are modelled estimates with the method shown, not costs disclosed by Walmart Associates Health and Welfare Plan. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 2.5 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), Walmart Associates Health and Welfare Plan, reported that a vender of its business associates (BA) experienced a cybersecurity incident that compromised the protected health information (PHI) of approximately 85,952 individuals. The PHI involved included names, addresses, dates of birth, and health insurance information. The CE notified HHS, affected individuals, the media, and provided substitute notice. The BA and its vendor strengthened its technical safeguards to better protect sensitive data.
Section F.5 / Modelled cost
85,952 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$13.8M
85,952 x $160
IBM 2026 customer PII, $192 per record
$16.5M
85,952 x $192
Method: individuals affected, as reported by Walmart Associates Health and Welfare Plan 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
Arkansas statute and the HIPAA rule
State notification statute
Arkansas: Ark. Code Ann. 4-110-101 et seq.
Personal Information Protection Act
- Notice to individuals
- In the most expedient time and manner possible and without unreasonable delay
- Attorney general threshold
- More than 1,000 Arkansas residents (At the time of individual notice or within 45 days of a harm determination, whichever is first)
- Private right of action
- No: No express private right of action under PIPA
- Penalty
- Up to $10,000 per violation under the Deceptive Trade Practices Act; willful violations are a misdemeanor
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
Arkansas filings closest in size
Neighbours by size rank among Arkansas 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 entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Highlands Oncology Group PAOpen | Healthcare Provider | 111,766 | 1 Aug 2025 | |||
| Mainline Health Systems IncOpen | Healthcare Provider | 101,104 | 23 Jun 2025 | |||
| Mena Regional Health System | Healthcare Provider | 84,814 | 22 Nov 2022 | |||
| Regional Family Medicine | Healthcare Provider | 80,166 | 12 Dec 2023 | |||
| Highlands Oncology Group PA | Healthcare Provider | 55,297 | 22 Dec 2023 |
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 1470.
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.