Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing DC-20181106-veterans-health-administrationHHS OCR Breach Register, District of Columbia

Breach filing

Archived

Veterans Health Administration: 19,254 individuals, Nov 2018.

Veterans Health Administration reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 6 November 2018. The filing records the organisation as a healthcare provider in District of Columbia and lists 19,254 individuals affected, which makes it the 7th largest of the 33 District of Columbia filings on the register and the 68th largest of the 369 filings submitted nationally in 2018. Among the 2 District of Columbia filings made in 2018 it ranks 1st.

Individuals affected

19,254

As reported to HHS

Modelled cost (IBM 2025)

$3.08M

Method shown, not disclosed

Rank in DC

7th

of 33 District of Columbia filings

Rank in 2018

68th

of 369 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
19,254
Breach submission date
6 November 2018
Submission year
2018
Type of breach
Unauthorized Access/Disclosure
Location of breached information
Paper/Films
Business associate present
Yes
Portal status
listed in the HHS OCR breach portal archive
Rank in District of Columbia by size
7th of 33
Rank in 2018 nationally
68th of 369
District of Columbia median filing
2,416 individuals
Register id (derived)
DC-20181106-veterans-health-administration

Section F.2 / In context

Where this filing sits in District of Columbia and in 2018

OCR classifies the incident as unauthorized access or disclosure, with the breached information held in paper records or films. Unauthorized Access/Disclosure is the type recorded on 15 of the 33 District of Columbia filings (45%) and on 38% of all filings submitted in 2018. Paper/Films appears on 33% of District of Columbia filings.

A business associate is recorded as present on the filing, as it is on 27% of District of Columbia filings. At 19,254 individuals the breach is 8.0 times the District of Columbia median filing of 2,416 and 4.8 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.

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 19,254 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 $3.08M; the 2026 edition's $192 gives $3.70M. Both are modelled estimates with the method shown, not costs disclosed by Veterans Health Administration. 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.

On August 8, 2018, and September 4, 2018, the covered entity's (CE's) business associate (BA), Xerox Corporation, erroneously printed appointment reminder cards for patients that were mailed to another patient. The two incidents affected a total of 19,254 individuals and included demographic and clinical information. The CE/BA provided breach notification to HHS, affected individuals, and the media. To protect against any other printing misalignment incident, the BA instituted additional processes and preventative measures such as joint BA and CE review of templates and programming prior to printing and a match alert notification. OCR reviewed a copy of the BA agreement, the individual breach notification letter, as well as the security measures implemented to address risks and vulnerabilities. OCR obtained assurances that the CE implemented the corrective actions listed.

Section F.5 / Modelled cost

19,254 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$3.08M

19,254 x $160

IBM 2026 customer PII, $192 per record

$3.70M

19,254 x $192

Method: individuals affected, as reported by Veterans Health Administration 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 2018, topped up from other years where 2018 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Veterans Health AdministrationHealthcare Provider44,30814 Sep 2020
Foxhall Ob Gyn AssociatesHealthcare Provider27,00024 Jun 2022
Community ConnectionsOpenHealthcare Provider18,94911 Dec 2024
Community ConnectionsOpenHealthcare Provider18,94318 May 2026
Children's National Medical CenterHealthcare Provider72230 Mar 2018

Index / Companion schedules

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 4682.

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.