Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing MD-20150520-carefirst-blue-cross-blue-shieldHHS OCR Breach Register, Maryland

Breach filing

Archived

CareFirst Blue Cross Blue Shield: 1,300,000 individuals, May 2015.

CareFirst Blue Cross Blue Shield reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 20 May 2015. The filing records the organisation as a health plan in Maryland and lists 1,300,000 individuals affected, which makes it the 5th largest of the 170 Maryland filings on the register and the 6th largest of the 270 filings submitted nationally in 2015. Among the 8 Maryland filings made in 2015 it ranks 1st.

Individuals affected

1,300,000

As reported to HHS

Modelled cost (IBM 2025)

$208M

Upper bound, method shown

Rank in MD

5th

of 170 Maryland filings

Rank in 2015

6th

of 270 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
1,300,000
Breach submission date
20 May 2015
Submission year
2015
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 Maryland by size
5th of 170
Rank in 2015 nationally
6th of 270
Maryland median filing
4,792 individuals
Register id (derived)
MD-20150520-carefirst-blue-cross-blue-shield

Section F.2 / In context

Where this filing sits in Maryland and in 2015

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 117 of the 170 Maryland filings (69%) and on 21% of all filings submitted in 2015. Network Server appears on 45% of Maryland filings.

No business associate is recorded on the filing; 38% of Maryland filings do involve one. At 1,300,000 individuals the breach is 271 times the Maryland median filing of 4,792 and 325 times the national median of 4,000 across all 7,884 filings. It is one of 149 filings on the register of one million 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.

Maryland's breach notification statute (Md. Code, Com. Law 14-3504) requires notice to affected residents within 45 days after discovery or notification of the breach. Its attorney general threshold: all breaches (AG notified before individual notices are sent). 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 1,300,000 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 $208M; the 2026 edition's $192 gives $250M. Both are modelled estimates with the method shown, not costs disclosed by CareFirst Blue Cross Blue Shield. 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), CareFirst Blue Cross Blue Shield, reported that it was the victim of a cyberattack that affected the electronic protected health information (ePHI) of approximately 1.3 million individuals. The ePHI involved included names, health insurance information, usernames, email addresses, and dates of birth. The CE notified HHS, affected individuals, the media, and provided substitute notice. In response to the breach, the CE implemented additional administrative, technical, and security safeguards to better protect its ePHI. OCR obtained assurances that the CE implemented the corrective actions noted.

Section F.5 / Modelled cost

1,300,000 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$208M

1,300,000 x $160

IBM 2026 customer PII, $192 per record

$250M

1,300,000 x $192

Method: individuals affected, as reported by CareFirst Blue Cross Blue Shield 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

Maryland statute and the HIPAA rule

State notification statute

Maryland: Md. Code, Com. Law 14-3504

Notice to individuals
Within 45 days after discovery or notification of the breach
Attorney general threshold
All breaches (AG notified before individual notices are sent) (Before individual notifications are sent)
Private right of action
No: No PROA under the breach statute; AG enforcement only
Penalty
Unfair or deceptive trade practice; up to $10,000 per violation, $25,000 per repeat violation

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

Maryland filings closest in size

Neighbours by size rank among Maryland filings in 2015, topped up from other years where 2015 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Insightin Health, Inc.OpenBusiness Associate1,949,53416 Jan 2026
Anne Arundel DermatologyOpenHealthcare Provider1,905,00011 Jul 2025
Frederick HealthOpenHealthcare Provider934,32628 Mar 2025
Saint Agnes Health Care, Inc.Healthcare Provider24,96724 Apr 2015
Anne Arundel Health SystemHealthcare Provider2,2088 Oct 2015

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 5836.

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.