Breach filing
ArchivedNorwood Clinic: 228,000 individuals, Feb 2022.
Norwood Clinic reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 25 February 2022. The filing records the organisation as a healthcare provider in Tennessee and lists 228,000 individuals affected, which makes it the 26th largest of the 196 Tennessee filings on the register and the 59th largest of the 718 filings submitted nationally in 2022. Among the 18 Tennessee filings made in 2022 it ranks 4th.
Individuals affected
228,000
As reported to HHS
Modelled cost (IBM 2025)
$36.5M
Upper bound, method shown
Rank in TN
26th
of 196 Tennessee filings
Rank in 2022
59th
of 718 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
- 228,000
- Breach submission date
- 25 February 2022
- Submission year
- 2022
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Electronic Medical Record
- Business associate present
- No
- State
- Tennessee (TN)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Tennessee by size
- 26th of 196
- Rank in 2022 nationally
- 59th of 718
- Tennessee median filing
- 3,371 individuals
- Register id (derived)
- TN-20220225-norwood-clinic
Section F.2 / In context
Where this filing sits in Tennessee and in 2022
OCR classifies the incident as a hacking or IT incident, with the breached information held in an electronic medical record system. Hacking/IT Incident is the type recorded on 121 of the 196 Tennessee filings (62%) and on 79% of all filings submitted in 2022. Electronic Medical Record appears on 4% of Tennessee filings.
No business associate is recorded on the filing; 36% of Tennessee filings do involve one. At 228,000 individuals the breach is 68 times the Tennessee median filing of 3,371 and 57 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.
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 228,000 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 $36.5M; the 2026 edition's $192 gives $43.8M. Both are modelled estimates with the method shown, not costs disclosed by Norwood Clinic. 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.
On October 22, 2021, Norwood discovered that it was the victim of a cyber attack that resulted in the unauthorized access of data stored on its network. Immediately after discovering the incident, Norwood took steps to secure and safely restore its systems and operations. In addition, Norwood engaged cybersecurity experts to conduct a thorough forensics investigation to determine the nature and scope of the incident and to assist in the remediation efforts. The investigation revealed that an unauthorized party gained access to Norwood's servers that stored patient information. However, the investigation was unable to confirm the specific information that may have been accessed. Therefore, out of an abundance of caution, Norwood is providing notice to all of its patients, regardless of whether their information was in fact subject to unauthorized access or acquisition. Norwood has no reason to believe that any individual's information has been misused as a result of this event.
Section F.5 / Modelled cost
228,000 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$36.5M
228,000 x $160
IBM 2026 customer PII, $192 per record
$43.8M
228,000 x $192
Method: individuals affected, as reported by Norwood Clinic 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 2022, topped up from other years where 2022 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Molecular Pathology Laboratory Network, Inc. | Healthcare Provider | 339,471 | 3 Mar 2022 | |||
| The Stern Cardiovascular Foundation, Inc. | Healthcare Provider | 270,645 | 5 Nov 2022 | |||
| Urgent Team Holdings | Healthcare Provider | 166,601 | 31 Mar 2022 | |||
| Dyersburg Family Walk-In Clinic, LLC dba Reelfoot Family Walk-In Clinic | Healthcare Provider | 58,562 | 23 Sep 2022 |
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 2643.
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.