Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing MD-20180313-special-agents-mutual-benefit-associatioHHS OCR Breach Register, Maryland

Breach filing

Archived

Special Agents Mutual Benefit Association: 13,942 individuals, Mar 2018.

Special Agents Mutual Benefit Association reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 13 March 2018. The filing records the organisation as a health plan in Maryland and lists 13,942 individuals affected, which makes it the 56th largest of the 170 Maryland filings on the register and the 86th largest of the 369 filings submitted nationally in 2018. Among the 9 Maryland filings made in 2018 it ranks 3rd.

Individuals affected

13,942

As reported to HHS

Modelled cost (IBM 2025)

$2.23M

Method shown, not disclosed

Rank in MD

56th

of 170 Maryland filings

Rank in 2018

86th

of 369 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
13,942
Breach submission date
13 March 2018
Submission year
2018
Type of breach
Unauthorized Access/Disclosure
Location of breached information
Paper/Films
Business associate present
No
Portal status
listed in the HHS OCR breach portal archive
Rank in Maryland by size
56th of 170
Rank in 2018 nationally
86th of 369
Maryland median filing
4,792 individuals
Register id (derived)
MD-20180313-special-agents-mutual-benefit-associatio

Section F.2 / In context

Where this filing sits in Maryland and in 2018

OCR classifies the incident as unauthorized access or disclosure, with the breached information held in paper records or films. Unauthorized Access/Disclosure is the type recorded on 33 of the 170 Maryland filings (19%) and on 38% of all filings submitted in 2018. Paper/Films appears on 9% of Maryland filings.

No business associate is recorded on the filing; 38% of Maryland filings do involve one. At 13,942 individuals the breach is 2.9 times the Maryland median filing of 4,792 and 3.5 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.

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 13,942 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 $2.23M; the 2026 edition's $192 gives $2.68M. Both are modelled estimates with the method shown, not costs disclosed by Special Agents Mutual Benefit Association. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.4 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), Special Agents Mutual Benefits Association, impermissibly disclosed the protected health information (PHI) of 1,394 individuals to the wrong subscribers when it distributed Form 1095-B notices for the 2017 tax year. The CE provided breach notification to HHS, the media, and affected individuals. The CE also offered affected individuals one year of complimentary credit monitoring and identity restoration services and established a toll-free assistance line to provide additional information regarding the incident, as well as steps to better protect against identity theft. Following the breach, the CE reissued corrected 1095-B forms. The CE terminated the relationship with the individual responsible for the programming error and implemented additional controls with its mailing vendor. During the investigation, OCR reviewed a copy of the CE's current risk assessment. OCR determined that corrective action had resolved the issues in this case.

Section F.5 / Modelled cost

13,942 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$2.23M

13,942 x $160

IBM 2026 customer PII, $192 per record

$2.68M

13,942 x $192

Method: individuals affected, as reported by Special Agents Mutual Benefit Association 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 2018, topped up from other years where 2018 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
LifeBridge Health, IncHealthcare Provider538,12715 May 2018
Capital Digestive Care, Inc.Healthcare Provider17,63923 Apr 2018
CareFirst Blue Cross Blue ShieldHealth Plan6,20026 Apr 2018
Westminster Ingleside King Farm Presbyterian Retirement Communities, Inc.Healthcare Provider5,22819 Jan 2018

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 4938.

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.