Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing TN-20250314-cdha-management-and-spark-dso-dba-chordHHS OCR Breach Register, Tennessee

Breach filing

Under investigation

CDHA Management, LLC and Spark DSO, LLC dba Chord Specialty Dental Partners: 173,430 individuals, Mar 2025.

CDHA Management, LLC and Spark DSO, LLC dba Chord Specialty Dental Partners reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 14 March 2025. The filing records the organisation as a healthcare provider in Tennessee and lists 173,430 individuals affected, which makes it the 27th largest of the 196 Tennessee filings on the register and the 58th largest of the 798 filings submitted nationally in 2025. Among the 25 Tennessee filings made in 2025 it ranks 2nd.

Individuals affected

173,430

As reported to HHS

Modelled cost (IBM 2025)

$27.7M

Upper bound, method shown

Rank in TN

27th

of 196 Tennessee filings

Rank in 2025

58th

of 798 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
Healthcare Provider
Individuals affected
173,430
Breach submission date
14 March 2025
Submission year
2025
Type of breach
Hacking/IT Incident
Location of breached information
Email
Business associate present
No
Portal status
listed by HHS OCR under Cases Currently Under Investigation
Rank in Tennessee by size
27th of 196
Rank in 2025 nationally
58th of 798
Tennessee median filing
3,371 individuals
Register id (derived)
TN-20250314-cdha-management-and-spark-dso-dba-chord

Section F.2 / In context

Where this filing sits in Tennessee and in 2025

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 121 of the 196 Tennessee filings (62%) and on 81% of all filings submitted in 2025. Email appears on 24% of Tennessee filings.

No business associate is recorded on the filing; 36% of Tennessee filings do involve one. At 173,430 individuals the breach is 51 times the Tennessee median filing of 3,371 and 43 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 by HHS OCR under Cases Currently Under Investigation. OCR has not published a closing summary, so this page is limited to the fields on the filing itself; the archive entry that follows a closed investigation usually adds a short account of what was exposed and what the entity did afterwards.

Tennessee's breach notification statute (Tenn. Code Ann. 47-18-2107) requires notice to affected residents immediately, but no later than 45 days from discovery or notification. Its attorney general threshold: no mandatory AG notification for private-sector breaches. 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 173,430 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 $27.7M; the 2026 edition's $192 gives $33.3M. Both are modelled estimates with the method shown, not costs disclosed by CDHA Management, LLC and Spark DSO, LLC dba Chord Specialty Dental Partners. 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.5 / Modelled cost

173,430 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$27.7M

173,430 x $160

IBM 2026 customer PII, $192 per record

$33.3M

173,430 x $192

Method: individuals affected, as reported by CDHA Management, LLC and Spark DSO, LLC dba Chord Specialty Dental Partners 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

Tennessee statute and the HIPAA rule

State notification statute

Tennessee: Tenn. Code Ann. 47-18-2107

Notice to individuals
Immediately, but no later than 45 days from discovery or notification
Attorney general threshold
No mandatory AG notification for private-sector breaches
Private right of action
Yes: Affected customers may sue to recover damages and obtain injunctive relief
Penalty
AG may pursue civil penalties, injunctive relief, and restitution; class actions restricted

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

Tennessee filings closest in size

Neighbours by size rank among Tennessee filings in 2025, topped up from other years where 2025 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
United Seating and Mobility, LLC d/b/a NumotionHealthcare Provider529,0047 Mar 2025
Mid-South Pulmonary & Sleep Specialists P.C.OpenHealthcare Provider70,21130 Dec 2025
Artemis Healthcare Inc.Healthcare Provider45,86723 Dec 2025

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-under-investigation__2026-08-28.csv, export row 606.

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.