Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing PA-20200601-city-of-philadelphiaHHS OCR Breach Register, Pennsylvania

Breach filing

Archived

City of Philadelphia: 233,543 individuals, Jun 2020.

City of Philadelphia reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 1 June 2020. The filing records the organisation as a health plan in Pennsylvania and lists 233,543 individuals affected, which makes it the 22nd largest of the 339 Pennsylvania filings on the register and the 35th largest of the 663 filings submitted nationally in 2020. Among the 40 Pennsylvania filings made in 2020 it ranks 3rd.

Individuals affected

233,543

As reported to HHS

Modelled cost (IBM 2025)

$37.4M

Upper bound, method shown

Rank in PA

22nd

of 339 Pennsylvania filings

Rank in 2020

35th

of 663 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
233,543
Breach submission date
1 June 2020
Submission year
2020
Type of breach
Hacking/IT Incident
Location of breached information
Email
Business associate present
No
Portal status
listed in the HHS OCR breach portal archive
Rank in Pennsylvania by size
22nd of 339
Rank in 2020 nationally
35th of 663
Pennsylvania median filing
3,905 individuals
Register id (derived)
PA-20200601-city-of-philadelphia

Section F.2 / In context

Where this filing sits in Pennsylvania and in 2020

OCR classifies the incident as a hacking or IT incident, with the breached information held in email. Hacking/IT Incident is the type recorded on 228 of the 339 Pennsylvania filings (67%) and on 69% of all filings submitted in 2020. Email appears on 24% of Pennsylvania filings.

No business associate is recorded on the filing; 34% of Pennsylvania filings do involve one. At 233,543 individuals the breach is 60 times the Pennsylvania median filing of 3,905 and 58 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.

Pennsylvania's breach notification statute (73 Pa. Stat. 2301 et seq.) requires notice to affected residents without unreasonable delay. Its attorney general threshold: more than 500 Pennsylvania 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 233,543 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 $37.4M; the 2026 edition's $192 gives $44.8M. Both are modelled estimates with the method shown, not costs disclosed by City of Philadelphia. 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), The City of Philadelphia, reported that multiple employees were the victims of an email phishing scheme that affected the electronic protected health information (ePHI) of 233,543 individuals. The CE notified HHS, affected individuals, the media, and posted substitute notice on its website. The CE provided complimentary credit and identity restoration services and provided a phone number for questions or concerns. In its mitigation efforts, the CE implemented additional administrative, technical, and security safeguards to better protect its ePHI, including retraining its workforce members on the proper methods of identifying fraudulent email communications.

Section F.5 / Modelled cost

233,543 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$37.4M

233,543 x $160

IBM 2026 customer PII, $192 per record

$44.8M

233,543 x $192

Method: individuals affected, as reported by City of Philadelphia 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

Pennsylvania statute and the HIPAA rule

State notification statute

Pennsylvania: 73 Pa. Stat. 2301 et seq.

Breach of Personal Information Notification Act (amended by Act 33 of 2024)

Notice to individuals
Without unreasonable delay
Attorney general threshold
More than 500 Pennsylvania residents (Without unreasonable delay (online portal))
Private right of action
Yes: Treated as an unfair or deceptive practice; consumers may pursue civil suits
Penalty
AG enforcement via civil actions, injunctive relief, civil penalties, and restitution

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

Pennsylvania filings closest in size

Neighbours by size rank among Pennsylvania filings in 2020, topped up from other years where 2020 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Einstein Healthcare NetworkHealthcare Provider353,6169 Oct 2020
Allegheny Health NetworkHealthcare Provider299,5073 Dec 2020
Prospect Medical Holdings (Crozer-Keystone Health System)Healthcare Provider177,02314 Aug 2020
The Guthrie ClinicHealthcare Provider92,0648 Sep 2020

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-archive__2026-08-28.csv, export row 3902.

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.