Breach filing
ArchivedTrusted Health Plans, Inc.: 200,665 individuals, Mar 2021.
Trusted Health Plans, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 26 March 2021. The filing records the organisation as a health plan in District of Columbia and lists 200,665 individuals affected, which makes it the 1st largest of the 33 District of Columbia filings on the register and the 57th largest of the 715 filings submitted nationally in 2021. Among the 4 District of Columbia filings made in 2021 it ranks 1st.
Individuals affected
200,665
As reported to HHS
Modelled cost (IBM 2025)
$32.1M
Upper bound, method shown
Rank in DC
1st
of 33 District of Columbia filings
Rank in 2021
57th
of 715 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
- 200,665
- Breach submission date
- 26 March 2021
- Submission year
- 2021
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- No
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in District of Columbia by size
- 1st of 33
- Rank in 2021 nationally
- 57th of 715
- District of Columbia median filing
- 2,416 individuals
- Register id (derived)
- DC-20210326-trusted-health-plans
Section F.2 / In context
Where this filing sits in District of Columbia and in 2021
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 12 of the 33 District of Columbia filings (36%) and on 76% of all filings submitted in 2021. Network Server appears on 36% of District of Columbia filings.
No business associate is recorded on the filing; 27% of District of Columbia filings do involve one. At 200,665 individuals the breach is 83 times the District of Columbia median filing of 2,416 and 50 times the national median of 4,000 across all 7,884 filings. It is one of 801 filings of 100,000 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.
District of Columbia's breach notification statute (D.C. Code 28-3851 et seq.) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: 50 or more District 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 200,665 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 $32.1M; the 2026 edition's $192 gives $38.5M. Both are modelled estimates with the method shown, not costs disclosed by Trusted Health Plans, Inc.. 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), Trusted Health Plans, reported that it was the victim of a ransomware attack that affected the electronic protected health information (ePHI) of 200,665 individuals. The ePHI involved included names, addresses, Social Security numbers, dates of birth, diagnoses/conditions, lab results, and other treatment information. The CE notified HHS, affected individuals, the media, and posted substitute notice on its website. In response to the breach, the CE strengthened its technical safeguards to better protect its ePHI.
Section F.5 / Modelled cost
200,665 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$32.1M
200,665 x $160
IBM 2026 customer PII, $192 per record
$38.5M
200,665 x $192
Method: individuals affected, as reported by Trusted Health Plans, Inc. 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
District of Columbia statute and the HIPAA rule
State notification statute
District of Columbia: D.C. Code 28-3851 et seq.
- Notice to individuals
- In the most expedient time possible and without unreasonable delay
- Attorney general threshold
- 50 or more District residents (No later than when residents are notified)
- Private right of action
- Yes: Treble damages or $1,500 per violation (whichever is greater), plus attorney fees
- Penalty
- Unfair or deceptive trade practice enforceable by the DC Attorney General; injunctive relief and restitution
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
District of Columbia filings closest in size
Neighbours by size rank among District of Columbia filings in 2021, topped up from other years where 2021 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Planned Parenthood of Metro Washington | Healthcare Provider | 142,982 | 20 Nov 2020 | |||
| Howard University College of Dentistry | Healthcare Provider | 80,915 | 23 Nov 2021 | |||
| Veterans Health Administration | Healthcare Provider | 46,677 | 30 Jan 2024 | |||
| Washington DC VA Medical Center | Healthcare Provider | 1,193 | 1 Nov 2021 |
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 3308.
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.