Breach filing
ArchivedIowa Total Care, Inc.: 11,581 individuals, Jun 2020.
Iowa Total Care, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 23 June 2020. The filing records the organisation as a health plan in Iowa and lists 11,581 individuals affected, which makes it the 37th largest of the 98 Iowa filings on the register and the 240th largest of the 663 filings submitted nationally in 2020. Among the 26 Iowa filings made in 2020 it ranks 5th.
Individuals affected
11,581
As reported to HHS
Modelled cost (IBM 2025)
$1.85M
Method shown, not disclosed
Rank in IA
37th
of 98 Iowa filings
Rank in 2020
240th
of 663 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
- 11,581
- Breach submission date
- 23 June 2020
- Submission year
- 2020
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Business associate present
- No
- State
- Iowa (IA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Iowa by size
- 37th of 98
- Rank in 2020 nationally
- 240th of 663
- Iowa median filing
- 4,336 individuals
- Register id (derived)
- IA-20200623-iowa-total-care
Section F.2 / In context
Where this filing sits in Iowa and in 2020
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in email. Unauthorized Access/Disclosure is the type recorded on 24 of the 98 Iowa filings (24%) and on 21% of all filings submitted in 2020. Email appears on 29% of Iowa filings.
No business associate is recorded on the filing; 34% of Iowa filings do involve one. At 11,581 individuals the breach is 2.7 times the Iowa median filing of 4,336 and 2.9 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.
Iowa's breach notification statute (Iowa Code Ch. 715C) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: 500 or more Iowa 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 11,581 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 $1.85M; the 2026 edition's $192 gives $2.22M. Both are modelled estimates with the method shown, not costs disclosed by Iowa Total Care, Inc.. 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.
The covered entity (CE), Iowa Total Care, reported that an employee inadvertently sent an email containing the electronic protected health information (ePHI) of approximately 11,581 individuals. The ePHI involved included names, dates of birth, health insurance information, diagnoses/conditions, 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 sanctioned the responsible employee and retrained its staff on the importance of safeguarding sensitive data. OCR obtained assurances that the CE implemented the corrective actions noted.
Section F.5 / Modelled cost
11,581 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$1.85M
11,581 x $160
IBM 2026 customer PII, $192 per record
$2.22M
11,581 x $192
Method: individuals affected, as reported by Iowa Total Care, 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
Iowa statute and the HIPAA rule
State notification statute
Iowa: Iowa Code Ch. 715C
Personal Information Security Breach Protection Act
- Notice to individuals
- In the most expedient time possible and without unreasonable delay
- Attorney general threshold
- 500 or more Iowa residents (Within five business days after notifying consumers)
- Private right of action
- No: No private right of action; AG enforcement only
- Penalty
- Unlawful practice under the consumer fraud statute; injunctive relief, civil penalties, and damages
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
Iowa filings closest in size
Neighbours by size rank among Iowa filings in 2020, topped up from other years where 2020 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Iowa Health System dba UnityPoint Health Affiliated Covered Entity | Healthcare Provider | 27,410 | 14 Sep 2020 | |||
| Tri-State Specialists, LLP | Healthcare Provider | 17,050 | 29 Oct 2020 | |||
| Monroe County Hospital & Clinics | Healthcare Provider | 8,487 | 17 Feb 2020 | |||
| Iowa Department of Human Services | Health Plan | 4,501 | 27 Jan 2020 |
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 3859.
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.