Breach filing
ArchivedConcordia Plan Services on behalf of the Concordia Health Plan: 12,500 individuals, Apr 2015.
Concordia Plan Services on behalf of the Concordia Health Plan reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 16 April 2015. The filing records the organisation as a health plan in Missouri and lists 12,500 individuals affected, which makes it the 53rd largest of the 164 Missouri filings on the register and the 46th largest of the 270 filings submitted nationally in 2015. Among the 5 Missouri filings made in 2015 it ranks 1st.
Individuals affected
12,500
As reported to HHS
Modelled cost (IBM 2025)
$2.00M
Method shown, not disclosed
Rank in MO
53rd
of 164 Missouri filings
Rank in 2015
46th
of 270 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
- 12,500
- Breach submission date
- 16 April 2015
- Submission year
- 2015
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- No
- State
- Missouri (MO)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Missouri by size
- 53rd of 164
- Rank in 2015 nationally
- 46th of 270
- Missouri median filing
- 4,800 individuals
- Register id (derived)
- MO-20150416-concordia-plan-services-on-behalf-of-con
Section F.2 / In context
Where this filing sits in Missouri and in 2015
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 100 of the 164 Missouri filings (61%) and on 21% of all filings submitted in 2015. Network Server appears on 38% of Missouri filings.
No business associate is recorded on the filing; 23% of Missouri filings do involve one. At 12,500 individuals the breach is 2.6 times the Missouri median filing of 4,800 and 3.1 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.
Missouri's breach notification statute (Mo. Rev. Stat. 407.1500) requires notice to affected residents without unreasonable delay. Its attorney general threshold: more than 1,000 Missouri consumers. 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 12,500 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 $2.00M; the 2026 edition's $192 gives $2.40M. Both are modelled estimates with the method shown, not costs disclosed by Concordia Plan Services on behalf of the Concordia Health Plan. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.4 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.
Blue Cross and Blue Shield of Minnesota, a business associate (BA) of Concordia Plan Services on behalf of the Concordia Health Plan, the covered entity (CE), stored the CE's electronic protected health information (ePHI) on computer servers belonging to its parent corporation, Anthem, Inc. Anthem experienced a series of cyberattacks which exposed the electronic protected health information (ePHI) of almost 79 million people, affecting 12,500 individuals who received health insurance from the CE. The ePHI involved included names, social security numbers, medical identification numbers, addresses, dates of birth, email addresses, and employment information. OCR reviewed the BA agreement and determined that it appeared to comply with the requirements of the HIPAA Privacy and Security Rules. OCR opened a separate review of Anthem, which resulted in Anthem agreeing to pay a monetary settlement and undertaking a robust corrective action plan to comply with the HIPAA Rules.
Section F.5 / Modelled cost
12,500 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$2.00M
12,500 x $160
IBM 2026 customer PII, $192 per record
$2.40M
12,500 x $192
Method: individuals affected, as reported by Concordia Plan Services on behalf of the Concordia Health Plan 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
Missouri statute and the HIPAA rule
State notification statute
Missouri: Mo. Rev. Stat. 407.1500
- Notice to individuals
- Without unreasonable delay
- Attorney general threshold
- More than 1,000 Missouri consumers (Without unreasonable delay)
- Private right of action
- No: AG has exclusive enforcement authority
- Penalty
- Up to $150,000 per breach (or series) for willful and knowing violations
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
Missouri filings closest in size
Neighbours by size rank among Missouri filings in 2015, topped up from other years where 2015 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Black River Medical Center | Healthcare Provider | 13,443 | 13 Jun 2018 | |||
| Phelps County Regional Medical Center d/b/a Phelps Health | Healthcare Provider | 12,602 | 21 Jun 2022 | |||
| Central Ozarks Medical CenterOpen | Healthcare Provider | 11,818 | 9 Jan 2026 | |||
| Centene Management Corporation | Health Plan | 8,208 | 15 Oct 2015 | |||
| Saint Louis County Department of Health | Healthcare Provider | 4,000 | 7 Jan 2015 |
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 5865.
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.