Breach filing
ArchivedTrillium Community Health Plan: 87,761 individuals, Mar 2021.
Trillium Community Health Plan reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 3 March 2021. The filing records the organisation as a health plan in Oregon and lists 87,761 individuals affected, which makes it the 10th largest of the 120 Oregon filings on the register and the 90th largest of the 715 filings submitted nationally in 2021. Among the 11 Oregon filings made in 2021 it ranks 2nd.
Individuals affected
87,761
As reported to HHS
Modelled cost (IBM 2025)
$14.0M
Method shown, not disclosed
Rank in OR
10th
of 120 Oregon filings
Rank in 2021
90th
of 715 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
- 87,761
- Breach submission date
- 3 March 2021
- Submission year
- 2021
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Oregon (OR)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Oregon by size
- 10th of 120
- Rank in 2021 nationally
- 90th of 715
- Oregon median filing
- 2,400 individuals
- Register id (derived)
- OR-20210303-trillium-community-health-plan
Section F.2 / In context
Where this filing sits in Oregon and in 2021
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 63 of the 120 Oregon filings (53%) and on 76% of all filings submitted in 2021. Network Server appears on 33% of Oregon filings.
A business associate is recorded as present on the filing, as it is on 23% of Oregon filings. At 87,761 individuals the breach is 37 times the Oregon median filing of 2,400 and 22 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.
Oregon's breach notification statute (ORS 646A.600 et seq.) requires notice to affected residents as soon as practicable but no later than 45 days after discovery. Its attorney general threshold: 250 or more Oregon residents. 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 87,761 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 $14.0M; the 2026 edition's $192 gives $16.9M. Both are modelled estimates with the method shown, not costs disclosed by Trillium Community Health Plan. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 2.5 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), Trillium Community Health Plan, reported that its business associate (BA) experienced a cyber-attack that affected the electronic protected health information (ePHI) of 87,761 individuals. The ePHI involved included names, addresses, dates of birth, health insurance information, diagnoses, medications prescribed, and other treatment information. The CE notified HHS, affected individuals, the media, and provided substitute notice. Following the breach, the CE provided complimentary identity protection services to affected individuals and terminated its contract with the BA.
Section F.5 / Modelled cost
87,761 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$14.0M
87,761 x $160
IBM 2026 customer PII, $192 per record
$16.9M
87,761 x $192
Method: individuals affected, as reported by Trillium Community 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
Oregon statute and the HIPAA rule
State notification statute
Oregon: ORS 646A.600 et seq.
Oregon Consumer Information Protection Act
- Notice to individuals
- As soon as practicable but no later than 45 days after discovery
- Attorney general threshold
- 250 or more Oregon residents (Within the 45-day notification window)
- Private right of action
- No: No express PROA; remedies may run through the Unlawful Trade Practices Act
- Penalty
- Up to $1,000 per violation; continuing violations up to $500,000
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
Oregon filings closest in size
Neighbours by size rank among Oregon filings in 2021, topped up from other years where 2021 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Oregon Anesthesiology Group, P.C. | Healthcare Provider | 750,500 | 6 Dec 2021 | |||
| Oregon Eye Specialists | Healthcare Provider | 42,612 | 13 Dec 2021 | |||
| One Community Health | Healthcare Provider | 39,865 | 22 Nov 2021 |
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 3360.
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.