Breach filing
ArchivedConifer Value-Based Care, LLC: 20,642 individuals, Jul 2022.
Conifer Value-Based Care, LLC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 26 July 2022. The filing records the organisation as a business associate in California and lists 20,642 individuals affected, which makes it the 176th largest of the 776 California filings on the register and the 245th largest of the 718 filings submitted nationally in 2022. Among the 53 California filings made in 2022 it ranks 15th.
Individuals affected
20,642
As reported to HHS
Modelled cost (IBM 2025)
$3.30M
Method shown, not disclosed
Rank in CA
176th
of 776 California filings
Rank in 2022
245th
of 718 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
- Business Associate
- Individuals affected
- 20,642
- Breach submission date
- 26 July 2022
- Submission year
- 2022
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- Yes
- State
- California (CA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in California by size
- 176th of 776
- Rank in 2022 nationally
- 245th of 718
- California median filing
- 3,553 individuals
- Register id (derived)
- CA-20220726-conifer-value-based-care
Section F.2 / In context
Where this filing sits in California and in 2022
OCR classifies the incident as a hacking or IT incident, with the breached information held in email. Hacking/IT Incident is the type recorded on 398 of the 776 California filings (51%) and on 79% of all filings submitted in 2022. Email appears on 20% of California filings.
A business associate is recorded as present on the filing, as it is on 33% of California filings. At 20,642 individuals the breach is 5.8 times the California median filing of 3,553 and 5.2 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.
California's breach notification statute (Cal. Civ. Code 1798.82) requires notice to affected residents within 30 calendar days of discovery (effective 1 January 2026, SB 446). Its attorney general threshold: more than 500 California 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 20,642 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 $3.30M; the 2026 edition's $192 gives $3.96M. Both are modelled estimates with the method shown, not costs disclosed by Conifer Value-Based Care, LLC. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.6 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), Conifer Value-Based Care, reported that several employees were the subjects of an email phishing scheme that affected the protected health information (PHI) of 20,642 individuals. The PHI involved included names, addresses, dates of birth, diagnoses, and other treatment information. The CE notified HHS and the affected individuals. In its mitigation efforts, the CE provided complimentary credit monitoring services and implemented additional administrative, technical, and security safeguards. Staff were retrained on email security.
Section F.5 / Modelled cost
20,642 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.30M
20,642 x $160
IBM 2026 customer PII, $192 per record
$3.96M
20,642 x $192
Method: individuals affected, as reported by Conifer Value-Based Care, LLC 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
California statute and the HIPAA rule
State notification statute
California: Cal. Civ. Code 1798.82
- Notice to individuals
- Within 30 calendar days of discovery (effective 1 January 2026, SB 446)
- Attorney general threshold
- More than 500 California residents (Within 15 calendar days after notifying affected consumers)
- Private right of action
- Yes: Under CCPA Civ. Code 1798.150 for breaches from failure to maintain reasonable security; $107-$799 per consumer per incident (CPI-adjusted from $100-$750, effective Jan 2025)
- Penalty
- CCPA civil penalties of $2,663 per violation, $7,988 per intentional violation (CPI-adjusted, effective Jan 2025); CCPA private right of action for security-failure breaches
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
California filings closest in size
Neighbours by size rank among California filings in 2022, topped up from other years where 2022 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| San Diego American Indian Health Center | Healthcare Provider | 30,721 | 15 Aug 2022 | |||
| Covenant Care California, LLC, on behalf of Wagner Heights Nursing and Rehabilitation Center | Healthcare Provider | 23,093 | 6 May 2022 | |||
| Alain A. Montiel, DDS | Healthcare Provider | 17,157 | 14 Oct 2022 | |||
| San Gorgonio Memorial Hospital | Healthcare Provider | 16,846 | 8 Dec 2022 |
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 2325.
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.