Breach filing
ArchivedCrystal Lake Clinic PC: 37,331 individuals, Apr 2021.
Crystal Lake Clinic PC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 9 April 2021. The filing records the organisation as a healthcare provider in Michigan and lists 37,331 individuals affected, which makes it the 46th largest of the 238 Michigan filings on the register and the 163rd largest of the 715 filings submitted nationally in 2021. Among the 24 Michigan filings made in 2021 it ranks 5th.
Individuals affected
37,331
As reported to HHS
Modelled cost (IBM 2025)
$5.97M
Method shown, not disclosed
Rank in MI
46th
of 238 Michigan filings
Rank in 2021
163rd
of 715 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
- 37,331
- Breach submission date
- 9 April 2021
- Submission year
- 2021
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- No
- State
- Michigan (MI)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Michigan by size
- 46th of 238
- Rank in 2021 nationally
- 163rd of 715
- Michigan median filing
- 3,754 individuals
- Register id (derived)
- MI-20210409-crystal-lake-clinic-pc
Section F.2 / In context
Where this filing sits in Michigan and in 2021
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 148 of the 238 Michigan filings (62%) and on 76% of all filings submitted in 2021. Network Server appears on 45% of Michigan filings.
No business associate is recorded on the filing; 30% of Michigan filings do involve one. At 37,331 individuals the breach is 9.9 times the Michigan median filing of 3,754 and 9.3 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. The archive entry carries no closing summary.
Michigan's breach notification statute (MCL 445.72) requires notice to affected residents without unreasonable delay. Its attorney general threshold: not currently required (pending SB 360 would require it at 100+ 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 37,331 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 $5.97M; the 2026 edition's $192 gives $7.17M. Both are modelled estimates with the method shown, not costs disclosed by Crystal Lake Clinic PC. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.1 times the sector average.
Section F.5 / Modelled cost
37,331 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$5.97M
37,331 x $160
IBM 2026 customer PII, $192 per record
$7.17M
37,331 x $192
Method: individuals affected, as reported by Crystal Lake Clinic PC 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
Michigan statute and the HIPAA rule
State notification statute
Michigan: MCL 445.72
Identity Theft Protection Act
- Notice to individuals
- Without unreasonable delay
- Attorney general threshold
- Not currently required (pending SB 360 would require it at 100+ residents)
- Private right of action
- No: No PROA under the statute; other theories such as negligence may apply
- Penalty
- Up to $250 per failed notification, capped at $750,000 per breach event
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
Michigan filings closest in size
Neighbours by size rank among Michigan filings in 2021, topped up from other years where 2021 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| McLaren Health Care Corporation | Healthcare Provider | 64,600 | 16 Jul 2021 | |||
| Covenant HealthCare | Healthcare Provider | 47,178 | 19 Feb 2021 | |||
| Mendelson Kornblum Orthopedics, Spine & Pain Specialists | Healthcare Provider | 28,658 | 5 Mar 2021 | |||
| Family Medical Center of Michigan | Healthcare Provider | 21,988 | 26 Aug 2021 |
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 3274.
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.