Breach filing
ArchivedColorado Department of Health Care Policy & Financing: 4,091,794 individuals, Aug 2023.
Colorado Department of Health Care Policy & Financing reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 11 August 2023. The filing records the organisation as a health plan in Colorado and lists 4,091,794 individuals affected, which makes it the 2nd largest of the 139 Colorado filings on the register and the 10th largest of the 746 filings submitted nationally in 2023. Among the 9 Colorado filings made in 2023 it ranks 2nd.
Individuals affected
4,091,794
As reported to HHS
Modelled cost (IBM 2025)
$655M
Upper bound, method shown
Rank in CO
2nd
of 139 Colorado filings
Rank in 2023
10th
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
- 4,091,794
- Breach submission date
- 11 August 2023
- Submission year
- 2023
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Colorado (CO)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Colorado by size
- 2nd of 139
- Rank in 2023 nationally
- 10th of 746
- Colorado median filing
- 3,845 individuals
- Register id (derived)
- CO-20230811-colorado-department-of-health-care-polic
Section F.2 / In context
Where this filing sits in Colorado 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 83 of the 139 Colorado filings (60%) and on 82% of all filings submitted in 2023. Network Server appears on 45% of Colorado filings.
A business associate is recorded as present on the filing, as it is on 24% of Colorado filings. At 4,091,794 individuals the breach is 1,064 times the Colorado median filing of 3,845 and 1,023 times the national median of 4,000 across all 7,884 filings. It is one of 149 filings on the register of one million or more individuals.
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.
Colorado's breach notification statute (C.R.S. 6-1-716) requires notice to affected residents within 30 days of determining a breach occurred. Its attorney general threshold: 500 or more Colorado 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 4,091,794 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 $655M; the 2026 edition's $192 gives $786M. Both are modelled estimates with the method shown, not costs disclosed by Colorado Department of Health Care Policy & Financing. Because the filing is above the roughly 100,000-record range in which the per-record figure is reliable, the result is an upper bound, not an estimate: fixed costs are spread across far more records at this scale.
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), Colorado Department of Health Care Policy & Financing, reported that a software application used by its business associate (BA) exposed the protected health information (PHI) of 4,091,794 individuals. The PHI involved included names, dates of birth, addresses, Social Security numbers, diagnoses, claims and health insurance information, and other treatment information. The CE notified HHS, affected individuals, the media, and provided substitute notice. In response to the breach, the CE provided complimentary credit monitoring services and the CE and BA implemented additional administrative, technical, and security safeguards to better protect PHI.
Section F.5 / Modelled cost
4,091,794 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$655M
4,091,794 x $160
IBM 2026 customer PII, $192 per record
$786M
4,091,794 x $192
Method: individuals affected, as reported by Colorado Department of Health Care Policy & Financing 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
Colorado statute and the HIPAA rule
State notification statute
Colorado: C.R.S. 6-1-716
- Notice to individuals
- Within 30 days of determining a breach occurred
- Attorney general threshold
- 500 or more Colorado residents (Within the same 30-day window)
- Private right of action
- No: Only the Colorado Attorney General may enforce
- Penalty
- Treated as a deceptive trade practice; up to $20,000 per violation with no aggregate cap
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
Colorado filings closest in size
Neighbours by size rank among Colorado 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 |
|---|---|---|---|---|---|---|
| Welltok, Inc. | Business Associate | 14,782,887 | 6 Nov 2023 | |||
| University of Colorado Hospital Authority | Healthcare Provider | 49,881 | 17 Jan 2023 | |||
| Denver Public Schools Medical Plans | Health Plan | 35,068 | 3 Mar 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 1570.
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.