Breach filing
ArchivedCogent Healthcare, Inc.: 32,000 individuals, Aug 2013.
Cogent Healthcare, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 30 August 2013. The filing records the organisation as a business associate in Tennessee and lists 32,000 individuals affected, which makes it the 48th largest of the 196 Tennessee filings on the register and the 15th largest of the 277 filings submitted nationally in 2013. Among the 8 Tennessee filings made in 2013 it ranks 1st.
Individuals affected
32,000
As reported to HHS
Modelled cost (IBM 2025)
$5.12M
Method shown, not disclosed
Rank in TN
48th
of 196 Tennessee filings
Rank in 2013
15th
of 277 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
- 32,000
- Breach submission date
- 30 August 2013
- Submission year
- 2013
- Type of breach
- Theft
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Tennessee (TN)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Tennessee by size
- 48th of 196
- Rank in 2013 nationally
- 15th of 277
- Tennessee median filing
- 3,371 individuals
- Register id (derived)
- TN-20130830-cogent-healthcare
Section F.2 / In context
Where this filing sits in Tennessee and in 2013
OCR classifies the incident as theft, with the breached information held in a network server. Theft is the type recorded on 25 of the 196 Tennessee filings (13%) and on 48% of all filings submitted in 2013. Network Server appears on 43% of Tennessee filings.
A business associate is recorded as present on the filing, as it is on 36% of Tennessee filings. At 32,000 individuals the breach is 9.5 times the Tennessee median filing of 3,371 and 8.0 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.
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 32,000 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 $5.12M; the 2026 edition's $192 gives $6.14M. Both are modelled estimates with the method shown, not costs disclosed by Cogent Healthcare, Inc.. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.9 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.
Cogent Healthcare, Inc., a business associate (BA) providing management services for 24 providers of hospitalist services, submitted a breach report to HHS on behalf of these covered entities. The BA's privacy officer found that protected health information (PHI) for which the BA was responsible was accessible on a File Transfer Protocol (FTP) Internet site. The PHI involved in the breach affected approximately 32,151 individuals and included patients' names, physicians' names, dates of birth, diagnoses, treatment summaries, medical histories, medical record numbers and related information.
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\OCR determined that the reporting entity is a BA and the incident occurred prior to the September 23, 2013, enforcement date. OCR provided the BA with technical assistance regarding current HIPAA Privacy and Security Rule BA requirements.
\
\
Section F.5 / Modelled cost
32,000 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$5.12M
32,000 x $160
IBM 2026 customer PII, $192 per record
$6.14M
32,000 x $192
Method: individuals affected, as reported by Cogent Healthcare, Inc. 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 2013, topped up from other years where 2013 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Advent Health Partners, Inc. | Business Associate | 37,183 | 6 Jan 2022 | |||
| Lucent Health Solutions, LLC | Business Associate | 37,000 | 30 Jan 2025 | |||
| Wakefield & Associates, LLC | Business Associate | 31,751 | 30 Jan 2026 | |||
| HOPE Family Health | Healthcare Provider | 6,932 | 30 Sep 2013 | |||
| Foundations Recovery Network | Healthcare Provider | 5,690 | 15 Aug 2013 |
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 6380.
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.