Breach filing
ArchivedIndependence Blue Cross, LLC: 16,762 individuals, Sep 2018.
Independence Blue Cross, LLC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 17 September 2018. The filing records the organisation as a business associate in Pennsylvania and lists 16,762 individuals affected, which makes it the 94th largest of the 339 Pennsylvania filings on the register and the 74th largest of the 369 filings submitted nationally in 2018. Among the 11 Pennsylvania filings made in 2018 it ranks 3rd.
Individuals affected
16,762
As reported to HHS
Modelled cost (IBM 2025)
$2.68M
Method shown, not disclosed
Rank in PA
94th
of 339 Pennsylvania filings
Rank in 2018
74th
of 369 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
- 16,762
- Breach submission date
- 17 September 2018
- Submission year
- 2018
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Other
- Business associate present
- Yes
- State
- Pennsylvania (PA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Pennsylvania by size
- 94th of 339
- Rank in 2018 nationally
- 74th of 369
- Pennsylvania median filing
- 3,905 individuals
- Register id (derived)
- PA-20180917-independence-blue-cross
Section F.2 / In context
Where this filing sits in Pennsylvania and in 2018
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in another location. Unauthorized Access/Disclosure is the type recorded on 56 of the 339 Pennsylvania filings (17%) and on 38% of all filings submitted in 2018. Other appears on 6% of Pennsylvania filings.
A business associate is recorded as present on the filing, as it is on 34% of Pennsylvania filings. At 16,762 individuals the breach is 4.3 times the Pennsylvania median filing of 3,905 and 4.2 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.
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 16,762 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 $2.68M; the 2026 edition's $192 gives $3.22M. Both are modelled estimates with the method shown, not costs disclosed by Independence Blue Cross, LLC. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.5 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.
On July 19, 2018, the covered entity (CE) learned that an employee uploaded a file containing limited member information to a public-facing website that was publicly accessible between April 23, 2018, and July 20, 2018. The types of protected health information involved in the breach included demographic, clinical, and health claims information for approximately 16,762 subscribers. The CE immediately took steps to ensure the file was permanently removed from the website, and launched an investigation to determine the nature and scope of this incident, working with a forensics investigation firm. The CE noted that the website involved was under development by the employee and was not well known or marketed to the public. The CE undertook multiple efforts to obtain data from the website hosting company, but efforts did not yield meaningful results, as the company hosting the website was not able to provide any data to the CE for the period of time that the file was accessible. The CE provided breach notification to HHS, affected individuals, and the media and provided credit monitoring services to those affected. OCR reviewed the individual breach notification letters, as well as the security measures implemented to address risks and vulnerabilities. OCR obtained assurances that the CE implemented the corrective actions listed.
Section F.5 / Modelled cost
16,762 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$2.68M
16,762 x $160
IBM 2026 customer PII, $192 per record
$3.22M
16,762 x $192
Method: individuals affected, as reported by Independence Blue Cross, 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
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 2018, topped up from other years where 2018 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| The May Eye Care Center | Healthcare Provider | 30,000 | 11 Oct 2018 | |||
| Carpenters Benefit Funds of Philadelphia | Health Plan | 20,015 | 31 Aug 2018 | |||
| Tandigm Health | Business Associate | 7,376 | 21 Nov 2018 | |||
| The Children's Hospital of Philadelphia | Healthcare Provider | 5,368 | 23 Oct 2018 |
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 4732.
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.