Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing MI-20260105-mid-michigan-medical-billing-serviceHHS OCR Breach Register, Michigan

Breach filing

Under investigation

Mid Michigan Medical Billing Service, Inc.: 28,185 individuals, Jan 2026.

Mid Michigan Medical Billing Service, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 5 January 2026. The filing records the organisation as a business associate in Michigan and lists 28,185 individuals affected, which makes it the 51st largest of the 238 Michigan filings on the register and the 81st largest of the 441 filings submitted nationally in 2026. Among the 16 Michigan filings made in 2026 it ranks 3rd.

Individuals affected

28,185

As reported to HHS

Modelled cost (IBM 2025)

$4.51M

Method shown, not disclosed

Rank in MI

51st

of 238 Michigan filings

Rank in 2026

81st

of 441 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
Business Associate
Individuals affected
28,185
Breach submission date
5 January 2026
Submission year
2026
Type of breach
Hacking/IT Incident
Location of breached information
Network Server
Business associate present
Yes
Portal status
listed by HHS OCR under Cases Currently Under Investigation
Rank in Michigan by size
51st of 238
Rank in 2026 nationally
81st of 441
Michigan median filing
3,754 individuals
Register id (derived)
MI-20260105-mid-michigan-medical-billing-service

Section F.2 / In context

Where this filing sits in Michigan and in 2026

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 86% of all filings submitted in 2026. Network Server appears on 45% of Michigan filings.

A business associate is recorded as present on the filing, as it is on 30% of Michigan filings. At 28,185 individuals the breach is 7.5 times the Michigan median filing of 3,754 and 7.0 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 by HHS OCR under Cases Currently Under Investigation. OCR has not published a closing summary, so this page is limited to the fields on the filing itself; the archive entry that follows a closed investigation usually adds a short account of what was exposed and what the entity did afterwards.

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 28,185 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 $4.51M; the 2026 edition's $192 gives $5.41M. Both are modelled estimates with the method shown, not costs disclosed by Mid Michigan Medical Billing Service, Inc.. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.8 times the sector average.

Section F.5 / Modelled cost

28,185 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$4.51M

28,185 x $160

IBM 2026 customer PII, $192 per record

$5.41M

28,185 x $192

Method: individuals affected, as reported by Mid Michigan Medical Billing Service, Inc. 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 2026, topped up from other years where 2026 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Hematology Oncology ConsultantsOpenHealthcare Provider62,97224 Apr 2026
Exclusive Physicians PLLCOpenHealthcare Provider58,0006 Mar 2026
Optalis Management SolutionsOpenHealthcare Provider13,72329 Jun 2026
Waterford Surgical CenterOpenHealthcare Provider9,00030 Mar 2026

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-under-investigation__2026-08-28.csv, export row 294.

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.