Breach filing
ArchivedCommonwealth Health Corporation: 697,800 individuals, Mar 2017.
Commonwealth Health Corporation reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 1 March 2017. The filing records the organisation as a healthcare provider in Kentucky and lists 697,800 individuals affected, which makes it the 3rd largest of the 124 Kentucky filings on the register and the 1st largest of the 358 filings submitted nationally in 2017. Among the 10 Kentucky filings made in 2017 it ranks 1st.
Individuals affected
697,800
As reported to HHS
Modelled cost (IBM 2025)
$112M
Upper bound, method shown
Rank in KY
3rd
of 124 Kentucky filings
Rank in 2017
1st
of 358 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
- 697,800
- Breach submission date
- 1 March 2017
- Submission year
- 2017
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Other Portable Electronic Device
- Business associate present
- No
- State
- Kentucky (KY)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Kentucky by size
- 3rd of 124
- Rank in 2017 nationally
- 1st of 358
- Kentucky median filing
- 3,663 individuals
- Register id (derived)
- KY-20170301-commonwealth-health
Section F.2 / In context
Where this filing sits in Kentucky and in 2017
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in another portable electronic device. Unauthorized Access/Disclosure is the type recorded on 41 of the 124 Kentucky filings (33%) and on 35% of all filings submitted in 2017. Other Portable Electronic Device appears on 10% of Kentucky filings.
No business associate is recorded on the filing; 28% of Kentucky filings do involve one. At 697,800 individuals the breach is 190 times the Kentucky median filing of 3,663 and 174 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.
Kentucky's breach notification statute (KRS 365.732) requires notice to affected residents without unreasonable delay, consistent with determining the scope of the breach. Its attorney general threshold: no general AG requirement (reporting agencies at more than 1,000 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 697,800 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 $112M; the 2026 edition's $192 gives $134M. Both are modelled estimates with the method shown, not costs disclosed by Commonwealth Health Corporation. 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.
Commonwealth Health Corporation, the covered entity (CE), discovered that, in August 2014 and February 2015, an employee impermissibly disclosed the protected health information (PHI) of 117,425 patients to a vendor. The types of PHI included billing information, patients' names, addresses, social security numbers, health insurance information, diagnoses, procedure codes and charges for medical services. The CE sent timely breach notification to HHS. Pursuant to a law enforcement delay, the CE did not send individual notification, media notification or post notification on its website until March 21, 2017, and March 24, 2017. In response to the breach, the CE sanctioned the party responsible for the breach, retrained staff, adopted new policies and procedures, revised existing policies and procedures, and formalized existing procedures that were not previously in writing. OCR also provided technical assistance regarding safeguards for reactivating users in its IT system. OCR obtained assurances that the CE implemented the corrective actions listed above.
Section F.5 / Modelled cost
697,800 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$112M
697,800 x $160
IBM 2026 customer PII, $192 per record
$134M
697,800 x $192
Method: individuals affected, as reported by Commonwealth Health Corporation 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
Kentucky statute and the HIPAA rule
State notification statute
Kentucky: KRS 365.732
- Notice to individuals
- Without unreasonable delay, consistent with determining the scope of the breach
- Attorney general threshold
- No general AG requirement (reporting agencies at more than 1,000 residents)
- Private right of action
- No: No express PROA; KRS 446.070 may allow recovery for statutory violations
- Penalty
- Limited private-sector enforcement; AG action under consumer protection statutes
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
Kentucky filings closest in size
Neighbours by size rank among Kentucky filings in 2017, topped up from other years where 2017 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| PharMerica Corporation | Healthcare Provider | 5,815,591 | 12 May 2023 | |||
| Norton Healthcare Inc. | Healthcare Provider | 2,500,000 | 7 Jul 2023 | |||
| CorrectCare Integrated Health, Inc. | Business Associate | 502,089 | 31 Oct 2022 | |||
| Pulmonary Specialists of Louisville, PSC | Healthcare Provider | 32,000 | 27 Nov 2017 | |||
| Ashland Women's Health | Healthcare Provider | 19,727 | 4 Apr 2017 |
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 5298.
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.