Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing IN-20230412-cummins-behavioral-health-systemsHHS OCR Breach Register, Indiana

Breach filing

Archived

Cummins Behavioral Health Systems: 154,285 individuals, Apr 2023.

Cummins Behavioral Health Systems reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 12 April 2023. The filing records the organisation as a healthcare provider in Indiana and lists 154,285 individuals affected, which makes it the 16th largest of the 200 Indiana filings on the register and the 122nd largest of the 746 filings submitted nationally in 2023. Among the 15 Indiana filings made in 2023 it ranks 1st.

Individuals affected

154,285

As reported to HHS

Modelled cost (IBM 2025)

$24.7M

Upper bound, method shown

Rank in IN

16th

of 200 Indiana filings

Rank in 2023

122nd

of 746 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
154,285
Breach submission date
12 April 2023
Submission year
2023
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 Indiana by size
16th of 200
Rank in 2023 nationally
122nd of 746
Indiana median filing
3,600 individuals
Register id (derived)
IN-20230412-cummins-behavioral-health-systems

Section F.2 / In context

Where this filing sits in Indiana and in 2023

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 119 of the 200 Indiana filings (60%) and on 82% of all filings submitted in 2023. Network Server appears on 42% of Indiana filings.

No business associate is recorded on the filing; 31% of Indiana filings do involve one. At 154,285 individuals the breach is 43 times the Indiana median filing of 3,600 and 39 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.

Indiana's breach notification statute (Ind. Code 24-4.9) requires notice to affected residents without unreasonable delay, no more than 45 days after discovery. Its attorney general threshold: all qualifying breaches. 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 154,285 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 $24.7M; the 2026 edition's $192 gives $29.6M. Both are modelled estimates with the method shown, not costs disclosed by Cummins Behavioral Health Systems. 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), Cummins Behavioral Health Systems, reported that it experienced a ransomware attack the affected the protected health information (PHI) of 154,285 individuals. The PHI involved included names, addresses, dates of birth, Social Security numbers, diagnoses/conditions, medications, and other treatment information. In response to the breach, the CE implemented additional administrative and technical safeguards. OCR provided the CE with technical assistance.

Section F.5 / Modelled cost

154,285 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$24.7M

154,285 x $160

IBM 2026 customer PII, $192 per record

$29.6M

154,285 x $192

Method: individuals affected, as reported by Cummins Behavioral Health Systems 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

Indiana statute and the HIPAA rule

State notification statute

Indiana: Ind. Code 24-4.9

Notice to individuals
Without unreasonable delay, no more than 45 days after discovery
Attorney general threshold
All qualifying breaches (Within the 45-day consumer notification window)
Private right of action
No: Enforced exclusively by the Indiana Attorney General
Penalty
Up to $150,000 per deceptive act, plus investigation costs

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

Indiana filings closest in size

Neighbours by size rank among Indiana filings in 2023, topped up from other years where 2023 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Premier Healthcare, LLCHealthcare Provider205,7484 Mar 2016
RCR Technology CorporationBusiness Associate187,5331 Jul 2013
Meridian Health Services Corp.Healthcare Provider111,37227 Apr 2020
Indiana University HealthHealth Plan21,3834 Aug 2023
Community Health Network, Inc.Healthcare Provider20,77717 Nov 2023

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 1839.

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.