Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing MN-20250428-minnesota-epilepsy-groupHHS OCR Breach Register, Minnesota

Breach filing

Under investigation

Minnesota Epilepsy Group: 38,401 individuals, Apr 2025.

Minnesota Epilepsy Group reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 28 April 2025. The filing records the organisation as a healthcare provider in Minnesota and lists 38,401 individuals affected, which makes it the 33rd largest of the 189 Minnesota filings on the register and the 172nd largest of the 798 filings submitted nationally in 2025. Among the 18 Minnesota filings made in 2025 it ranks 3rd.

Individuals affected

38,401

As reported to HHS

Modelled cost (IBM 2025)

$6.14M

Method shown, not disclosed

Rank in MN

33rd

of 189 Minnesota filings

Rank in 2025

172nd

of 798 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
38,401
Breach submission date
28 April 2025
Submission year
2025
Type of breach
Hacking/IT Incident
Location of breached information
Network Server
Business associate present
No
Portal status
listed by HHS OCR under Cases Currently Under Investigation
Rank in Minnesota by size
33rd of 189
Rank in 2025 nationally
172nd of 798
Minnesota median filing
3,159 individuals
Register id (derived)
MN-20250428-minnesota-epilepsy-group

Section F.2 / In context

Where this filing sits in Minnesota and in 2025

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 114 of the 189 Minnesota filings (60%) and on 81% of all filings submitted in 2025. Network Server appears on 43% of Minnesota filings.

No business associate is recorded on the filing; 35% of Minnesota filings do involve one. At 38,401 individuals the breach is 12 times the Minnesota median filing of 3,159 and 9.6 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.

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 38,401 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 $6.14M; the 2026 edition's $192 gives $7.37M. Both are modelled estimates with the method shown, not costs disclosed by Minnesota Epilepsy Group. 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

38,401 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$6.14M

38,401 x $160

IBM 2026 customer PII, $192 per record

$7.37M

38,401 x $192

Method: individuals affected, as reported by Minnesota Epilepsy Group 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 2025, topped up from other years where 2025 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Community Dental Care, Inc.OpenHealthcare Provider134,90328 Mar 2025
Pediatric Home Respiratory Services, LLC d/b/a Pediatric Home ServiceHealthcare Provider41,7926 Jan 2025
Nice Healthcare Management Company, IncOpenHealthcare Provider10,00010 Mar 2025
Bigfork Valley HospitalOpenHealthcare Provider8,49625 Mar 2025

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 567.

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.