Breach filing
ArchivedHawai'i Medical Service Association: 10,179 individuals, Jan 2016.
Hawai'i Medical Service Association reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 15 January 2016. The filing records the organisation as a health plan in Hawaii and lists 10,179 individuals affected, which makes it the 12th largest of the 22 Hawaii filings on the register and the 82nd largest of the 328 filings submitted nationally in 2016. It was the only Hawaii filing in 2016.
Individuals affected
10,179
As reported to HHS
Modelled cost (IBM 2025)
$1.63M
Method shown, not disclosed
Rank in HI
12th
of 22 Hawaii filings
Rank in 2016
82nd
of 328 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
- 10,179
- Breach submission date
- 15 January 2016
- Submission year
- 2016
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Paper/Films
- Business associate present
- No
- State
- Hawaii (HI)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Hawaii by size
- 12th of 22
- Rank in 2016 nationally
- 82nd of 328
- Hawaii median filing
- 14,369 individuals
- Register id (derived)
- HI-20160115-hawaii-medical-service-association
Section F.2 / In context
Where this filing sits in Hawaii and in 2016
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 5 of the 22 Hawaii filings (23%) and on 40% of all filings submitted in 2016. Paper/Films appears on 27% of Hawaii filings.
No business associate is recorded on the filing; 27% of Hawaii filings do involve one. At 10,179 individuals the breach is 0.7 times the Hawaii median filing of 14,369 and 2.5 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.
Hawaii's breach notification statute (HRS Ch. 487N) requires notice to affected residents without unreasonable delay. Its attorney general threshold: 1,000 or more Hawaii residents (written notice to the Office of Consumer Protection). 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 10,179 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 $1.63M; the 2026 edition's $192 gives $1.95M. Both are modelled estimates with the method shown, not costs disclosed by Hawai'i Medical Service Association. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.3 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.
Between April and November 2015, the covered entity (CE), Hawai'i Medical Service Association, mistakenly sent care management letters to incorrect addresses, affecting approximately 10,179 patients' protected health information (PHI). The types of PHI involved in the breach included names and the implied suggestion that individuals may have certain medical conditions. The CE provided breach notification to HHS, affected individuals, and the media. Following the breach, the CE updated its risk analysis and risk management plan and enhanced physical security. OCR obtained assurances that the CE implemented the corrective actions noted above.
Section F.5 / Modelled cost
10,179 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$1.63M
10,179 x $160
IBM 2026 customer PII, $192 per record
$1.95M
10,179 x $192
Method: individuals affected, as reported by Hawai'i Medical Service Association 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
Hawaii statute and the HIPAA rule
State notification statute
Hawaii: HRS Ch. 487N
- Notice to individuals
- Without unreasonable delay
- Attorney general threshold
- 1,000 or more Hawaii residents (written notice to the Office of Consumer Protection)
- Private right of action
- Yes: Individuals may sue for actual damages plus reasonable attorney fees
- Penalty
- Up to $2,500 per violation enforceable by the AG or Office of Consumer Protection
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
Hawaii filings closest in size
Neighbours by size rank among Hawaii filings in 2016, topped up from other years where 2016 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Hawaii Independent Physicians Association | Business Associate | 18,770 | 22 Jun 2021 | |||
| Hawaiian Eye Center | Healthcare Provider | 14,524 | 19 Dec 2022 | |||
| Hale Makua Health Services | Healthcare Provider | 14,369 | 29 Oct 2025 | |||
| East Hawaii Rehab, Inc. DBA Lehua Physical Therapy and RehabOpen | Healthcare Provider | 8,472 | 28 Feb 2025 | |||
| Sleep Center Hawaii | Healthcare Provider | 5,396 | 12 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 5674.
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.