Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing HI-20210420-orthopedic-associates-of-hawaiiHHS OCR Breach Register, Hawaii

Breach filing

Archived

Orthopedic Associates of Hawaii: 138,000 individuals, Apr 2021.

Orthopedic Associates of Hawaii reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 20 April 2021. The filing records the organisation as a healthcare provider in Hawaii and lists 138,000 individuals affected, which makes it the 1st largest of the 22 Hawaii filings on the register and the 72nd largest of the 715 filings submitted nationally in 2021. Among the 4 Hawaii filings made in 2021 it ranks 1st.

Individuals affected

138,000

As reported to HHS

Modelled cost (IBM 2025)

$22.1M

Upper bound, method shown

Rank in HI

1st

of 22 Hawaii filings

Rank in 2021

72nd

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
Healthcare Provider
Individuals affected
138,000
Breach submission date
20 April 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 Hawaii by size
1st of 22
Rank in 2021 nationally
72nd of 715
Hawaii median filing
14,369 individuals
Register id (derived)
HI-20210420-orthopedic-associates-of-hawaii

Section F.2 / In context

Where this filing sits in Hawaii 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 13 of the 22 Hawaii filings (59%) and on 76% of all filings submitted in 2021. Network Server appears on 45% of Hawaii filings.

No business associate is recorded on the filing; 27% of Hawaii filings do involve one. At 138,000 individuals the breach is 9.6 times the Hawaii median filing of 14,369 and 35 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.

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 138,000 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 $22.1M; the 2026 edition's $192 gives $26.5M. Both are modelled estimates with the method shown, not costs disclosed by Orthopedic Associates of Hawaii. 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), Orthopedic Associates of Hawaii, reported that it was the victim of a ransomware attack that affected the electronic protected health information (ePHI) of approximately 138,000 individuals. The ePHI involved included names, addresses, dates of birth, drivers' license numbers, Social Security numbers, claims and financial information, and treatment information. The CE notified HHS, affected individuals, the media, and provided substitute notice. In response to the breach, the CE implemented additional technical and administrative safeguards to better protect its ePHI. During the investigation, OCR provided the CE with technical assistance.

Section F.5 / Modelled cost

138,000 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$22.1M

138,000 x $160

IBM 2026 customer PII, $192 per record

$26.5M

138,000 x $192

Method: individuals affected, as reported by Orthopedic Associates of Hawaii 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 2021, topped up from other years where 2021 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Community Clinic of Maui, Inc. dba Malama I Ke Ola Health CenterHealthcare Provider123,81626 Sep 2024
Hawaii Radiologic Associates, Ltd.OpenHealthcare Provider43,91625 Oct 2024
Aloha Laser VisionHealthcare Provider43,26317 Jun 2022
All Access OrthoHealthcare Provider25,00020 Apr 2021
Hawaii Independent Physicians AssociationBusiness Associate18,77022 Jun 2021

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 3255.

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.