Breach filing
ArchivedKentucky Counseling Center, LLC: 16,440 individuals, Feb 2019.
Kentucky Counseling Center, LLC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 11 February 2019. The filing records the organisation as a healthcare provider in Kentucky and lists 16,440 individuals affected, which makes it the 25th largest of the 124 Kentucky filings on the register and the 119th largest of the 511 filings submitted nationally in 2019. Among the 9 Kentucky filings made in 2019 it ranks 1st.
Individuals affected
16,440
As reported to HHS
Modelled cost (IBM 2025)
$2.63M
Method shown, not disclosed
Rank in KY
25th
of 124 Kentucky filings
Rank in 2019
119th
of 511 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
- 16,440
- Breach submission date
- 11 February 2019
- Submission year
- 2019
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Electronic Medical Record
- Business associate present
- No
- State
- Kentucky (KY)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Kentucky by size
- 25th of 124
- Rank in 2019 nationally
- 119th of 511
- Kentucky median filing
- 3,663 individuals
- Register id (derived)
- KY-20190211-kentucky-counseling-center
Section F.2 / In context
Where this filing sits in Kentucky and in 2019
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in an electronic medical record system. Unauthorized Access/Disclosure is the type recorded on 41 of the 124 Kentucky filings (33%) and on 27% of all filings submitted in 2019. Electronic Medical Record appears on 3% of Kentucky filings.
No business associate is recorded on the filing; 28% of Kentucky filings do involve one. At 16,440 individuals the breach is 4.5 times the Kentucky median filing of 3,663 and 4.1 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.
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 16,440 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 $2.63M; the 2026 edition's $192 gives $3.16M. Both are modelled estimates with the method shown, not costs disclosed by Kentucky Counseling Center, LLC. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.5 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), Kentucky Counseling Center, LLC, discovered that a former contractor sent a former staff member an email containing a list of 16,440 of the CE's patients. The email contained protected health information (PHI), including demographic and health insurance information. The CE provided breach notification to HHS, affected individuals, and the media and also notified the FBI. In response to the breach, the CE adopted encryption technology, implemented two-factor authentication and strengthened password requirements. In addition, the CE retrained contractors and employees on HIPAA and added additional controls to its electronic medical record (EMR) system. The CE conducted a risk assessment and developed new policies and procedures. OCR obtained assurances that the CE implemented the corrective actions listed above.
Section F.5 / Modelled cost
16,440 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$2.63M
16,440 x $160
IBM 2026 customer PII, $192 per record
$3.16M
16,440 x $192
Method: individuals affected, as reported by Kentucky Counseling Center, LLC 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 2019, topped up from other years where 2019 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Ashland Women's Health | Healthcare Provider | 19,727 | 4 Apr 2017 | |||
| Integranetics | Business Associate | 18,871 | 7 Feb 2011 | |||
| Insurance ACE/Humana Inc. | Health Plan | 15,003 | 5 Jun 2024 | |||
| Associates in Dermatology, PLLC | Healthcare Provider | 9,020 | 16 Jul 2019 | |||
| Family Physicians of Winter Park, Inc. | Healthcare Provider | 8,429 | 8 Jan 2019 |
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 4582.
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.