Breach filing
ArchivedCritical Care, Pulmonary and Sleep Associates, PLLP: 23,377 individuals, Jan 2019.
Critical Care, Pulmonary and Sleep Associates, PLLP reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 21 January 2019. The filing records the organisation as a healthcare provider in Colorado and lists 23,377 individuals affected, which makes it the 33rd largest of the 139 Colorado filings on the register and the 98th largest of the 511 filings submitted nationally in 2019. Among the 9 Colorado filings made in 2019 it ranks 2nd.
Individuals affected
23,377
As reported to HHS
Modelled cost (IBM 2025)
$3.74M
Method shown, not disclosed
Rank in CO
33rd
of 139 Colorado filings
Rank in 2019
98th
of 511 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
- Healthcare Provider
- Individuals affected
- 23,377
- Breach submission date
- 21 January 2019
- Submission year
- 2019
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Colorado (CO)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Colorado by size
- 33rd of 139
- Rank in 2019 nationally
- 98th of 511
- Colorado median filing
- 3,845 individuals
- Register id (derived)
- CO-20190121-critical-care-pulmonary-and-sleep-associ
Section F.2 / In context
Where this filing sits in Colorado and in 2019
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 83 of the 139 Colorado filings (60%) and on 61% of all filings submitted in 2019. Email appears on 24% of Colorado filings.
No business associate is recorded on the filing; 24% of Colorado filings do involve one. At 23,377 individuals the breach is 6.1 times the Colorado median filing of 3,845 and 5.8 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.
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 23,377 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 $3.74M; the 2026 edition's $192 gives $4.49M. Both are modelled estimates with the method shown, not costs disclosed by Critical Care, Pulmonary and Sleep Associates, PLLP. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.7 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.
Critical Care Pulmonary and Sleep Associates, PLLP, the covered entity (CE), reported a phishing attack led to the compromise of six of the CE's email accounts. The CE determined that third parties may have had access to the electronic protected health information (ePHI) in such email accounts leading to the breach of 23,377 individuals' ePHI. The ePHI contained in the email accounts included names, addresses, dates of birth, driver's license numbers, claims information, financial information, diagnoses/conditions, lab results, medications, and other treatment information. In response to the breach incident, Critical Care Pulmonary and Sleep Associates notified affected individuals of the breach, notified prominent media outlets of the breach, and sanctioned the workforce member who fell victim to the phishing attack. The CE also implemented additional technical controls to better safeguard its ePHI, updated its security awareness and HIPAA policies and procedures, and retrained its workforce.
OCR provided the CE with technical assistance.
Section F.5 / Modelled cost
23,377 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.74M
23,377 x $160
IBM 2026 customer PII, $192 per record
$4.49M
23,377 x $192
Method: individuals affected, as reported by Critical Care, Pulmonary and Sleep Associates, PLLP 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 2019, topped up from other years where 2019 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Elizabeth Family Health | Healthcare Provider | 28,375 | 22 Nov 2019 | |||
| Sunrise Community Health | Healthcare Provider | 18,404 | 5 Dec 2019 | |||
| Perfect Teeth Yale, P.C. | Healthcare Provider | 15,000 | 19 Sep 2019 |
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 4609.
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.