Breach filing
ArchivedMinnesota Department of Human Services: 20,800 individuals, Oct 2018.
Minnesota Department of Human Services reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 9 October 2018. The filing records the organisation as a health plan in Minnesota and lists 20,800 individuals affected, which makes it the 43rd largest of the 189 Minnesota filings on the register and the 61st largest of the 369 filings submitted nationally in 2018. Among the 10 Minnesota filings made in 2018 it ranks 2nd.
Individuals affected
20,800
As reported to HHS
Modelled cost (IBM 2025)
$3.33M
Method shown, not disclosed
Rank in MN
43rd
of 189 Minnesota filings
Rank in 2018
61st
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
- 20,800
- Breach submission date
- 9 October 2018
- Submission year
- 2018
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Minnesota (MN)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Minnesota by size
- 43rd of 189
- Rank in 2018 nationally
- 61st of 369
- Minnesota median filing
- 3,159 individuals
- Register id (derived)
- MN-20181009-minnesota-department-of-human-services
Section F.2 / In context
Where this filing sits in Minnesota and in 2018
OCR classifies the incident as a hacking or IT incident, with the breached information held in email. Hacking/IT Incident is the type recorded on 114 of the 189 Minnesota filings (60%) and on 45% of all filings submitted in 2018. Email appears on 29% of Minnesota filings.
No business associate is recorded on the filing; 35% of Minnesota filings do involve one. At 20,800 individuals the breach is 6.6 times the Minnesota median filing of 3,159 and 5.2 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.
Minnesota's breach notification statute (Minn. Stat. 325E.61) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: no general AG requirement (reporting agencies at 500+ residents within 48 hours). 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 20,800 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 $3.33M; the 2026 edition's $192 gives $3.99M. Both are modelled estimates with the method shown, not costs disclosed by Minnesota Department of Human Services. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.6 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), Minnesota Department of Human Services, reported that several employees were victims of a series of email phishing schemes. This breach affected 20,320 individuals. The protected health information (PHI) involved included names, dates of birth, addresses, Social Security numbers, medications prescribed, and diagnoses/conditions. The CE notified HHS, affected individuals, and the media. Following this breach, the CE implemented additional security, technical and administrative safeguards to better protect its PHI. The CE also retrained its staff. OCR obtained assurances that the CE implemented the corrective actions noted.
Section F.5 / Modelled cost
20,800 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.33M
20,800 x $160
IBM 2026 customer PII, $192 per record
$3.99M
20,800 x $192
Method: individuals affected, as reported by Minnesota Department of Human Services 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
Minnesota statute and the HIPAA rule
State notification statute
Minnesota: Minn. Stat. 325E.61
- Notice to individuals
- In the most expedient time possible and without unreasonable delay
- Attorney general threshold
- No general AG requirement (reporting agencies at 500+ residents within 48 hours)
- Private right of action
- No: Only the Minnesota Attorney General may enforce
- Penalty
- Up to $25,000 per violation; contractual waivers of notification are void
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
Minnesota filings closest in size
Neighbours by size rank among Minnesota 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 entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Ramsey County | Healthcare Provider | 117,905 | 11 Dec 2018 | |||
| Associates in Psychiatry and Psychology | Healthcare Provider | 6,546 | 18 May 2018 | |||
| Virtual Radiologic Professionals, LLC | Healthcare Provider | 2,568 | 19 Dec 2018 |
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 4711.
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.