Breach filing
ArchivedMinnesota Department of Human Services: 303,965 individuals, Jan 2026.
Minnesota Department of Human Services reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 16 January 2026. The filing records the organisation as a health plan in Minnesota and lists 303,965 individuals affected, which makes it the 8th largest of the 189 Minnesota filings on the register and the 20th largest of the 441 filings submitted nationally in 2026. Among the 13 Minnesota filings made in 2026 it ranks 1st.
Individuals affected
303,965
As reported to HHS
Modelled cost (IBM 2025)
$48.6M
Upper bound, method shown
Rank in MN
8th
of 189 Minnesota filings
Rank in 2026
20th
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
- Health Plan
- Individuals affected
- 303,965
- Breach submission date
- 16 January 2026
- Submission year
- 2026
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Minnesota (MN)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Minnesota by size
- 8th of 189
- Rank in 2026 nationally
- 20th of 441
- Minnesota median filing
- 3,159 individuals
- Register id (derived)
- MN-20260116-minnesota-department-of-human-services
Section F.2 / In context
Where this filing sits in Minnesota and in 2026
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in a network server. Unauthorized Access/Disclosure is the type recorded on 53 of the 189 Minnesota filings (28%) and on 13% of all filings submitted in 2026. Network Server appears on 43% of Minnesota filings.
A business associate is recorded as present on the filing, as it is on 35% of Minnesota filings. At 303,965 individuals the breach is 96 times the Minnesota median filing of 3,159 and 76 times the national median of 4,000 across all 7,884 filings. It is one of 801 filings of 100,000 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.
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 303,965 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 $48.6M; the 2026 edition's $192 gives $58.4M. Both are modelled estimates with the method shown, not costs disclosed by Minnesota Department of Human Services. 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), Minnesota Department of Human Services, reported that an employee of its business associate (BA) breached its network environment which affected the protected health information (PHI) of 303,965 individuals. The PHI involved included demographic information. The CE notified HHS, the affected individuals, the media, and provided substitute notice. In response to the breach, the CE provided complimentary credit monitoring services to the affected individuals and the CE and BA implemented additional administrative, technical, and security safeguards to better protect PHI.
Section F.5 / Modelled cost
303,965 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$48.6M
303,965 x $160
IBM 2026 customer PII, $192 per record
$58.4M
303,965 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 2026, topped up from other years where 2026 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Consulting Radiologists LTD. | Healthcare Provider | 583,824 | 14 Jun 2024 | |||
| University of Minnesota Physicians | Healthcare Provider | 310,666 | 30 Mar 2020 | |||
| Allina Health | Healthcare Provider | 199,389 | 11 Sep 2020 | |||
| Aitkin County Health and Human ServicesOpen | Business Associate | 83,114 | 17 Jun 2026 | |||
| Minnesota Epilepsy Group, P.A.Open | Healthcare Provider | 80,061 | 5 Jun 2026 |
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 127.
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.