Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing PR-20101109-medical-card-system-mcs-hmo-mcs-advantagHHS OCR Breach Register, Puerto Rico

Breach filing

Archived

Medical Card System/MCS-HMO/MCS Advantage/MCS Life: 115,000 individuals, Nov 2010.

Medical Card System/MCS-HMO/MCS Advantage/MCS Life reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 9 November 2010. The filing records the organisation as a business associate in Puerto Rico and lists 115,000 individuals affected, which makes it the 4th largest of the 32 Puerto Rico filings on the register and the 9th largest of the 199 filings submitted nationally in 2010. Among the 6 Puerto Rico filings made in 2010 it ranks 3rd.

Individuals affected

115,000

As reported to HHS

Modelled cost (IBM 2025)

$18.4M

Upper bound, method shown

Rank in PR

4th

of 32 Puerto Rico filings

Rank in 2010

9th

of 199 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
115,000
Breach submission date
9 November 2010
Submission year
2010
Type of breach
Unauthorized Access/Disclosure
Location of breached information
Other, Other Portable Electronic Device
Business associate present
Yes
Portal status
listed in the HHS OCR breach portal archive
Rank in Puerto Rico by size
4th of 32
Rank in 2010 nationally
9th of 199
Puerto Rico median filing
7,911 individuals
Register id (derived)
PR-20101109-medical-card-system-mcs-hmo-mcs-advantag

Section F.2 / In context

Where this filing sits in Puerto Rico and in 2010

OCR classifies the incident as unauthorized access or disclosure, with the breached information held in another location and another portable electronic device. Unauthorized Access/Disclosure is the type recorded on 8 of the 32 Puerto Rico filings (25%) and on 5% of all filings submitted in 2010. Other appears on 19% of Puerto Rico filings.

A business associate is recorded as present on the filing, as it is on 56% of Puerto Rico filings. At 115,000 individuals the breach is 15 times the Puerto Rico median filing of 7,911 and 29 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.

Puerto Rico is outside the site's 50-state statute table, so no state deadline is shown; the HIPAA Breach Notification Rule still applied, requiring notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.

Multiplying 115,000 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 $18.4M; the 2026 edition's $192 gives $22.1M. Both are modelled estimates with the method shown, not costs disclosed by Medical Card System/MCS-HMO/MCS Advantage/MCS Life. 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.

\N

Section F.5 / Modelled cost

115,000 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$18.4M

115,000 x $160

IBM 2026 customer PII, $192 per record

$22.1M

115,000 x $192

Method: individuals affected, as reported by Medical Card System/MCS-HMO/MCS Advantage/MCS Life 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

Puerto Rico statute and the HIPAA rule

State notification statute

Puerto Rico is outside the site's 50-state statute table. The HIPAA Breach Notification Rule applied regardless: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.

HIPAA breach penalties and the 60-day rule

Section F.7 / Peer filings

Puerto Rico filings closest in size

Neighbours by size rank among Puerto Rico filings in 2010, topped up from other years where 2010 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Puerto Rico Department of Health - Triple S Management Corp.Health Plan475,0004 Nov 2010
Triple-S Salud, Inc.Health Plan398,00018 Nov 2010
MSO of Puerto Rico, Inc.Business Associate1,90717 Feb 2010
Hospital Auxilio MutuoHealthcare Provider1,00013 Dec 2010

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 6992.

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.