Breach filing
ArchivedOptum360, LLC: 11,500,000 individuals, Jul 2019.
Optum360, LLC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 1 July 2019. The filing records the organisation as a business associate in Minnesota and lists 11,500,000 individuals affected, which makes it the 2nd largest of the 189 Minnesota filings on the register and the 1st largest of the 511 filings submitted nationally in 2019. Among the 24 Minnesota filings made in 2019 it ranks 1st.
Individuals affected
11,500,000
As reported to HHS
Modelled cost (IBM 2025)
$1.84B
Upper bound, method shown
Rank in MN
2nd
of 189 Minnesota filings
Rank in 2019
1st
of 511 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
- 11,500,000
- Breach submission date
- 1 July 2019
- Submission year
- 2019
- Type of breach
- Hacking/IT Incident
- 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
- 2nd of 189
- Rank in 2019 nationally
- 1st of 511
- Minnesota median filing
- 3,159 individuals
- Register id (derived)
- MN-20190701-optum360
Section F.2 / In context
Where this filing sits in Minnesota and in 2019
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 61% of all filings submitted in 2019. 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 11,500,000 individuals the breach is 3,640 times the Minnesota median filing of 3,159 and 2,875 times the national median of 4,000 across all 7,884 filings. It is one of 149 filings on the register of one million 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 11,500,000 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 $1.84B; the 2026 edition's $192 gives $2.21B. Both are modelled estimates with the method shown, not costs disclosed by Optum360, LLC. 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), Optum360, reported that its business associate (BA) was the victim of a cyber-attack that affected the electronic protected health information (ePHI) 11,574,452 individuals. The ePHI involved included names, addresses, phone numbers, dates of birth, Social Security numbers, financial information, and other treatment information. The CE notified HHS, affected individuals, the media, and posted substitute notice to its website. Following the discovery of the breach, the CE terminated its business relationship with the BA.
Section F.5 / Modelled cost
11,500,000 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$1.84B
11,500,000 x $160
IBM 2026 customer PII, $192 per record
$2.21B
11,500,000 x $192
Method: individuals affected, as reported by Optum360, LLC 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 2019, topped up from other years where 2019 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Change Healthcare, Inc. | Business Associate | 192,700,000 | 19 Jul 2024 | |||
| Pension Benefit Information, LLC | Business Associate | 1,866,694 | 14 Jul 2023 | |||
| MNGI Digestive Health, PA | Healthcare Provider | 767,670 | 24 Oct 2023 | |||
| TenX Systems, LLC d/b/a ResiDex Software | Business Associate | 90,000 | 7 Jun 2019 | |||
| Southeastern Minnesota Oral & Maxillofacial Surgery | Healthcare Provider | 80,000 | 22 Nov 2019 |
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 4392.
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.